Privacy Policy

Introduction

Aequitas Financial, LLC (“Aequitas Financial,” “AF,” “we,” “us,” or “our”) is a California state-registered investment adviser. We recognize that our relationships with clients are built on integrity, trust, and transparency. We are committed to protecting the privacy of every person who shares personal information with us.

This Privacy Policy explains what personal and financial information we collect, how we use and protect it, with whom we may share it, and the rights available to you under applicable federal and California law. This Policy applies to current clients, former clients, and prospective clients whose information we receive in connection with evaluating or providing financial planning or investment advisory services.

This Privacy Policy is provided to you in accordance with the Gramm-Leach-Bliley Act (GLBA), the Federal Trade Commission (FTC) Privacy Rule (16 C.F.R. Part 313), the California Financial Information Privacy Act (Cal. Fin. Code §§4050–4060, “SB-1”), and other applicable state and federal privacy laws.

1. Information We Collect

We collect nonpublic personal information (“NPI”) about you from the following sources:

Information You Provide Directly

• Identity information: full name, date of birth, Social Security number or Tax Identification Number, government-issued ID details
• Contact information: home address, email address, phone number
• Financial information: income, assets, liabilities, net worth, insurance coverage, tax returns, investment account statements, and employee benefit details
• Family and household information: marital status, dependents, estate planning details
• Goals, risk tolerance, and other information relevant to your financial plan

Information We Generate

• Financial plans, investment policy statements, and related analyses we prepare on your behalf
• Records of transactions, correspondence, and account activity
• Notes from client meetings and communications

Information Received from Third Parties

• Account data from custodians or other financial institutions you authorize us to access
• Information from your other advisers (attorneys, CPAs, insurance professionals) when you direct us to work with them
• Information from credit bureaus or public records when relevant to your engagement

Information Collected Through Our Website

When you visit our website, we may automatically collect certain technical information, including:

• IP address, browser type, device identifiers, and operating system
• Pages viewed, time spent on pages, and referring URLs
• Information you submit through contact forms, newsletter sign-ups, or other online tools

We may use cookies, web beacons, and similar tracking technologies to improve website functionality and understand how visitors use our site. You may configure your browser to refuse cookies, though some features of the site may not function properly if you do so.

Interactive tools and self-checks. If you complete an educational self-check tool on our site (such as the "high earner, not rich yet" self-check), we store the general, non-identifying ranges you select — for example household type, income band, and liquidity band — so we can understand which topics visitors find relevant. These responses are not linked to your identity unless you voluntarily provide your email address to receive a summary, in which case your email is stored alongside your responses and may be added to our email list. Self-check responses are educational in nature, do not create an advisory relationship, and are not used to provide individualized investment advice. You may email us at any time to request deletion of a submission.

2. How We Use Your Information

We use the information we collect to:

• Provide, personalize, and improve the financial planning and investment advisory services we offer
• Develop and monitor investment strategies aligned with your goals and risk profile
• Communicate with you regarding your account, our services, and updates relevant to your financial situation
• Fulfill our regulatory obligations as a California state-registered investment adviser under the California Corporations Code and related regulations
• Maintain accurate business records and comply with recordkeeping requirements
• Protect against fraud, unauthorized transactions, and legal liability
• Evaluate prospective client engagements

3. Information We Disclose

We do not sell your personal information to anyone, at any time, for any purpose.

We may disclose your NPI to nonaffiliated third parties only in the following limited circumstances:

Service Providers (No Opt-Out Required)

We may share NPI with companies or individuals who perform services on our behalf that are necessary to carry out your engagement with AF. These include, but are not limited to:

• Account custodians and broker-dealers who hold or execute transactions in your accounts
• Financial planning software, portfolio management, and reporting platforms
• Client relationship management (CRM) and document storage systems
• Cloud computing, data backup, and cybersecurity service providers
• Professional advisers such as compliance consultants, attorneys, and accountants who advise AF

All service providers with access to your NPI are subject to contractual confidentiality obligations and are permitted to use your information only for the purpose of providing services to AF on your behalf.

Legal and Regulatory Disclosures (No Opt-Out Required)

We may disclose your NPI as required or permitted by law, including:

• To comply with applicable federal or state law, regulation, or legal process
• To respond to regulatory inquiries or examinations from the California Department of Financial Protection and Innovation (DFPI) or other regulatory bodies
• To prevent fraud, protect against security threats, or enforce our legal rights

At Your Direction (No Opt-Out Required)

We may share your NPI with third parties you designate, including your attorney, CPA, insurance professional, or a named power of attorney, when you direct us to do so.

Business Transfers

In connection with a proposed or actual sale, merger, or transfer of all or a portion of our business, we may disclose your NPI to a prospective or actual successor firm. Any successor firm will be required to maintain this Privacy Policy or provide you with notice of a materially different policy and an opportunity to opt out.

Disclosures Requiring Your Opt-Out Right

If, in the future, AF were to share your NPI with a nonaffiliated third party for any purpose not described above and not otherwise excepted under the FTC Privacy Rule, we would notify you in advance and provide you with a reasonable opportunity to opt out of such sharing before it occurs. We currently have no such sharing arrangements.

4. California Financial Information Privacy Act (SB-1)

California Financial Code §§4050–4060 (“SB-1”) provides California residents with additional protections regarding the sharing of financial information with nonaffiliated third parties for marketing purposes.

Aequitas Financial does not share your NPI with nonaffiliated third parties for their own independent marketing or solicitation purposes. Because we do not engage in such sharing, the SB-1 opt-in consent requirement is not triggered. If AF ever determines that it wishes to share your NPI in a manner that would trigger SB-1’s opt-in requirement, we will contact you in advance and obtain your affirmative written consent before doing so.

5. Your Right to Opt Out

Under the FTC Privacy Rule (GLBA), you have the right to opt out of certain disclosures of your NPI to nonaffiliated third parties. As described in Section 3, Aequitas Financial’s current disclosures are limited to service providers and legally required disclosures, both of which are exempt from the opt-out requirement under the FTC Privacy Rule.

We will provide you with advance notice and a full opt-out opportunity if AF ever intends to disclose your NPI in a manner that is not currently covered by this Policy or that would otherwise trigger opt-out rights under applicable law.

To Exercise Your Opt-Out Right: Submit a written request to Taylor Bell, Chief Compliance Officer, by email at taylor@aequitasfp.com or by mail at the address listed in Section 13. We will process your request within a reasonable time, generally within 30 days of receipt.

6. How We Protect Your Information

The security of your personal information is a priority. We maintain a comprehensive data security program that includes:

Physical Safeguards

• Restricted access to physical locations where client records are stored
• Secure destruction of physical documents containing NPI

Electronic Safeguards

• Encryption of data in transit and at rest where technically feasible
• Password-protected and multi-factor-authenticated access to client systems and data
• Use of reputable, security-vetted software platforms for client data management
• Regular software updates and security patching

Procedural Safeguards

• Access to client NPI is limited to those with a legitimate business need
• Confidentiality agreements with all third-party service providers who access client NPI
• Periodic review of privacy and security practices

Despite these measures, no method of electronic transmission or storage is completely secure. While we strive to use commercially reasonable means to protect your information, we cannot guarantee absolute security.

7. Former Clients

When our client relationship ends, AF will continue to maintain the privacy and security of your NPI in accordance with this Privacy Policy for as long as we retain your records. We retain all records relating to former clients for the period required under applicable law, including California securities regulations and FTC recordkeeping requirements. Your NPI will not be sold or shared in a manner inconsistent with this Policy following the termination of our relationship.

8. California Consumer Privacy Act (CCPA/CPRA)

The California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, “CCPA/CPRA”), provides certain privacy rights to California residents, including the right to know, access, correct, and delete personal information.

Personal information that Aequitas Financial collects and uses in the ordinary course of providing investment advisory and financial planning services to individual clients is subject to the Gramm-Leach-Bliley Act and the FTC Privacy Rule. Pursuant to Cal. Civ. Code §1798.145(e), personal information collected, processed, sold, or disclosed in connection with the provision of financial services pursuant to GLBA is exempt from CCPA/CPRA to the extent of that GLBA coverage.

Aequitas Financial is a small, solo-practitioner firm. At the time this Policy was last revised, AF does not meet the CCPA/CPRA’s jurisdictional thresholds of: (a) annual gross revenues in excess of $25 million; (b) annually buying, selling, or sharing the personal information of 100,000 or more California consumers or households; or (c) deriving 50% or more of annual revenues from selling or sharing consumers’ personal information.

Accordingly, AF is not currently a “business” subject to the full obligations of CCPA/CPRA. Nonetheless, AF voluntarily commits to the data subject rights that are consistent with its current practices: we do not sell your personal information, you may request access to or deletion of your information by contacting our CCO, and we will honor such requests to the extent legally and operationally feasible.

9. California “Shine the Light” Disclosure

California Civil Code §1798.83 permits California residents who are our clients to request, once per calendar year, information about any personal information we have disclosed to third parties for their own direct marketing purposes during the preceding calendar year.

Aequitas Financial does not disclose personal information to nonaffiliated third parties for their own direct marketing purposes. Therefore, there is no information to report under this law. If you have questions about this, please contact our CCO using the information in Section 13.

10. Online Privacy — Website and “Do Not Track”

Our website may use analytics tools that collect non-personally-identifiable data about site usage, such as Google Analytics or similar platforms. This data is used in aggregated, anonymized form to improve our website and user experience and is not linked to individual client accounts.

California law (Bus. & Prof. Code §22575 et seq.) requires websites to disclose how they respond to “Do Not Track” (DNT) browser signals. At this time, our website does not have the technical capability to respond to DNT signals in a standardized way. We do not currently knowingly collect personal information from website visitors for third-party behavioral advertising purposes.

If you submit personal information through our website (e.g., via a contact form or newsletter sign-up), that information will be collected and used consistent with this Privacy Policy and applicable law.

11. Delivery of This Notice

In accordance with the FTC Privacy Rule, AF will:

• Provide a copy of this Privacy Policy to new clients at or before the time of establishing a client relationship
• Provide an annual notice to current clients describing our privacy practices

This notice may be delivered electronically (by email or secure portal) or in paper form. If you would prefer to receive the annual notice in a particular format, please notify our CCO.

An exception to the annual notice requirement applies if AF has not changed its privacy policies or practices since the most recent notice and limits its disclosures to those permitted under the FTC Privacy Rule’s service provider and legal exceptions. AF currently qualifies for this exception, and will provide a revised notice within a reasonable time if our policies materially change.

12. Updates to This Policy

We reserve the right to update this Privacy Policy at any time. If we make material changes to how we collect, use, or share your NPI, we will notify you at least 30 days before the change takes effect and provide you with a reasonable opportunity to opt out if the change would permit disclosures not currently covered by this Policy. The most current version of this Policy will be posted on our website and is available upon request.

13. Contact Us

If you have questions about this Privacy Policy, wish to exercise any of your rights described above, or would like to request a copy of this Policy in an alternative format, please contact:

We aim to respond to all privacy-related inquiries within 30 days of receipt.

This Privacy Policy is incorporated by reference into the Aequitas Financial, LLC Form ADV Part 2 Brochure.

© 2026 Aequitas Financial, LLC. All rights reserved. Additional information about Aequitas Financial, LLC is available in our Form ADV on the SEC’s Investment Adviser Public Disclosure website.