Privacy Policy

Breachway Investments, LLC ("Breachway," "we," "us," or "our") is an independent, fee-only Registered Investment Adviser. As a fiduciary, maintaining your trust and protecting your privacy is our highest priority. This Privacy Policy outlines how we collect, share, and protect your nonpublic personal information.

We collect personal information to provide you with comprehensive financial planning, investment management, and retirement consulting services, as well as to operate our BreachwayGO! automated investing platform. We do not sell your personal information to anyone.

1. Information We Collect

To deliver our advisory services effectively, we must collect certain nonpublic personal information about you. This information may include:

• Identifying Information: Name, date of birth, Social Security number, driver's license or passport details, and contact information (address, email, phone numbers).
• Financial Information: Income, net worth, tax returns, banking details, account balances, investment experience, and risk tolerance.
• Transaction Information: History of transactions in accounts managed or advised by us, including trading history, balances, and wire transfers.
• Digital Information: IP addresses, browser types, and usage data collected when you visit our website or use the BreachwayGO! platform.

2. How We Collect Information

We gather this information directly from you or through the following channels:

• Client agreements, onboarding forms, and financial planning questionnaires.
• Interactions with our advisory team during meetings, phone calls, or emails.
• Account applications and forms provided to our custodian, Charles Schwab Institutional.
• Information you input into our digital planning software or the BreachwayGO! platform.
• Your transactions with us or others connected to your advisory accounts.

3. How We Share Your Information

We only share your nonpublic personal information as necessary to provide our services and manage your accounts. We do not sell your data to third parties for marketing purposes. We may share your information with:

• Our Custodian: We share necessary information with Charles Schwab Institutional (or your designated custodian) to open accounts, execute trades, and process fund transfers on your behalf.
• Service Providers: We use third-party software and service providers for financial planning, portfolio reporting, compliance, and secure data storage. These providers are contractually obligated to protect your information and use it solely for the services they provide to Breachway.
• Your Designated Professionals: With your explicit consent, we may share information with your other professional advisors, such as your CPA or estate planning attorney, to coordinate your financial plan.
• Legal and Regulatory Authorities: We may disclose information when legally required by a subpoena, court order, or regulatory inquiry from state or federal agencies (e.g., the SEC or FINRA).

4. How We Protect Your Information

We implement strict physical, electronic, and procedural safeguards to protect your personal data from unauthorized access, alteration, or disclosure. These safeguards include:

• Utilizing secure, encrypted networks and software platforms for data transmission and storage.
• Restricting access to your personal information to only those employees and authorized agents who require it to provide you with our services.
• Requiring third-party service providers to maintain stringent security and confidentiality protocols.
• Maintaining secure office environments at our West Hartford, CT, and Charlestown, RI locations.

5. Website Privacy and Cookies

When you visit BreachwayInvestments.com or use BreachwayGO!, we may use cookies and similar tracking technologies to enhance your experience and analyze website traffic. Cookies do not capture personally identifiable information unless you explicitly provide it (for example, by filling out a contact form). You can adjust your web browser settings to refuse cookies, though some site features may not function optimally as a result.

6. Your Rights and Choices

Federal law gives you the right to limit some, but not all, sharing of your personal information. Because Breachway Investments only shares your information to conduct our everyday business purposes (such as processing transactions and maintaining your accounts), you cannot opt out of this specific sharing. However, if you have questions about what information we hold or need to update your financial profile, you may contact us at any time.

7. Former Clients

If you close your accounts or end your relationship with Breachway Investments, we will continue to adhere to the privacy policies and practices described in this notice. We retain client records as mandated by regulatory retention requirements.

8. Changes to this Policy

We reserve the right to modify this Privacy Policy at any time. We will notify active clients of any material changes to how we handle nonpublic personal information as required by law. The most current version of this policy will always be available on our website.