Privacy Policy

ANDBANC ADVISORY LLC (“ANDBANC,” “we,” “us,” or “our”), an investment adviser registered with the U.S. Securities and Exchange Commission (SEC File No. 801-79716; CRD No. 150463), respects your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard personal information when you visit andbanc-advisory.com (the “Site”), subscribe to our SMS alert programs, or otherwise use our services (collectively, the “Services”).

1. Information We Collect

1.1 Information You Provide Directly

• Contact information — name, email address, and mobile phone number when you subscribe, contact us, or enroll in SMS alerts.
• Account and billing information — subscription tier, billing contact details, and transaction history. Payment card data is processed by our third-party payment processor and is not stored on our systems.
• Advisory intake information — for portfolio management or consulting clients, information about your financial situation, objectives, and risk tolerance, collected under a written advisory agreement.
• Communications — the content of emails, forms, and other correspondence you send us.

1.2 Information Collected Automatically

• Usage data — pages visited, links clicked, referring URLs, and access times.
• Device data — browser type, operating system, IP address, and general location derived from it.
• Cookies and similar technologies — see Section 6.

2. How We Use Your Information

• To provide, operate, and bill for the Services, including delivering SMS alerts and briefings you requested;
• To verify your mobile number and administer opt-in/opt-out preferences;
• To respond to inquiries and provide customer support;
• To comply with legal and regulatory obligations, including books-and-records requirements applicable to SEC-registered investment advisers;
• To detect, prevent, and address fraud, abuse, and security incidents;
• To improve the Site and Services, including through aggregated, de-identified analytics;
• To send service-related notices (e.g., billing confirmations, changes to our terms). Marketing emails are sent only where permitted and always include an unsubscribe option.

3. SMS / Text Messaging Data

When you opt in to our SMS programs, we collect your mobile number, your consent record (timestamp, method, and disclosure presented), message delivery status, and your replies (such as STOP or HELP). We use this information solely to operate the messaging program, to comply with the Telephone Consumer Protection Act (TCPA) and carrier requirements, and to document consent.

4. How We Share Information

We do not sell your personal information. We share personal information only in the following circumstances:

• Service providers — vendors that perform functions on our behalf under contractual confidentiality obligations, such as payment processing, SMS delivery (aggregators and wireless carriers solely to route messages you requested), website hosting, and email delivery.
• Legal and regulatory — to the SEC, state securities regulators, law enforcement, or other parties when required by law, subpoena, examination, or to protect our rights and the safety of our users.
• Business transfers — in connection with a merger, acquisition, or sale of assets, subject to this Policy and notice where required.
• With your direction — when you ask us to share information, for example with your custodian or other professional advisers.

5. Data Retention

We retain personal information for as long as your subscription is active and thereafter as required by applicable law — including SEC recordkeeping rules for registered investment advisers (generally five years or more for advisory records) — and as necessary to resolve disputes and enforce agreements. SMS consent records are retained for the life of the messaging relationship plus the period required to demonstrate TCPA compliance.

6. Cookies and Tracking Technologies

The Site uses a limited set of cookies: strictly necessary cookies (session integrity and security) and, where enabled, privacy-respecting analytics cookies that help us understand aggregate usage. You may set your browser to refuse cookies; the Site will remain functional, though some convenience features may be affected. The Site does not respond to “Do Not Track” signals because no uniform industry standard exists.

7. Your Privacy Rights

Depending on your state of residence (including California under the CCPA/CPRA, Virginia, Colorado, Connecticut, Utah, and others), you may have some or all of the following rights regarding your personal information:

• Right to know/access — request the categories and specific pieces of personal information we hold about you;
• Right to deletion — request deletion of your personal information, subject to legal retention requirements (including SEC recordkeeping rules);
• Right to correction — request correction of inaccurate personal information;
• Right to opt out of sale/sharing — we do not sell or share personal information for cross-context behavioral advertising, so no opt-out is necessary;
• Right to non-discrimination — we will not discriminate against you for exercising any of these rights.

To exercise your rights, email [email protected] with the subject line “Privacy Request.” We will verify your identity (typically via the email address or phone number on file) and respond within the time required by applicable law. You may designate an authorized agent where permitted by law.

8. Data Security

We maintain administrative, technical, and physical safeguards appropriate to the sensitivity of the information we handle, including encryption in transit (TLS), access controls limited to personnel with a business need, and vendor due diligence. No method of transmission or storage is 100% secure; if we become aware of a breach affecting your personal information, we will notify you as required by law.

9. Third-Party Links

The Site may link to third-party websites (for example, the SEC’s Investment Adviser Public Disclosure site). We are not responsible for the privacy practices of third parties, and we encourage you to read their policies.

10. Children’s Privacy

The Services are directed to adults aged 18 and older. We do not knowingly collect personal information from children under 13 (or under 18 for SMS programs). If you believe a child has provided us information, contact us and we will delete it.

11. International Visitors

The Services are operated in the United States and intended for U.S. residents. If you access the Site from outside the United States, you understand that your information will be processed in the United States, which may have different data-protection laws than your jurisdiction.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The “Last Updated” date above reflects the most recent revision. Material changes will be announced on this page and, where appropriate, by email or SMS notice. Your continued use of the Services after an update constitutes acceptance of the revised Policy.

13. Contact Us

Questions, requests, or complaints regarding this Privacy Policy may be directed to: