Online Privacy Policy

The relationship between Evermay Wealth Management, LLC and its affiliated tax and business advisory firm Evermay Tax, LLC (collectively, “Evermay”, “we,” “our,” or “us”) and our clients is the most important asset of our firm. Evermay strives to maintain its clients’ trust and confidence in our firm, an essential aspect of which is our commitment to responsible management, use and protection of clients’ personal information to the best of our ability. Evermay continually updates and improves security standards and procedures to guard against anyone gaining unauthorized access to client’s information.

Evermay maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”). Through this policy and its underlying procedures, Evermay attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.

Evermay collects information about clients from the following sources, but not limited to the following sources, in connection with providing services:

(1) personal information received from clients, whether in person, in writing, via outside account aggregation as part of our Client Portal, with by telephone or otherwise, (2) personal information from transactions and (3) personal information from third-parties such as accountants, legal counsel, financial advisors, insurance agents, banking institutions, and brokerage firms. The personal information is used for, but not limited to, the following purposes:

(1) monitor, audit, evaluate, and other wise administer Evermay services,

(2) provide clients with access to protected areas of Evermay’s website (i.e. Evermay Client Portal),

(3) provide continuous service to clients and to conduct business processing functions including by providing personal information to our affiliates, contractors, service providers, or other third parties,

(4) assist with the administrative, marketing (including direct marketing), planning, or service development, quality control, or research purposes of Evermay and its contractors and service providers,

(5) communicate with you and respond to your inquiries,

(6) protect against, identify and prevent fraud, copyright infringement, unauthorized use and distribution of protected content, and other unlawful activity, claims and liabilities,

(7) perform data analyses (such as market and customer research),

(8) pursue Evermay’s legitimate interests,

(9) conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations, and our policies and terms, or

(10) for other purposes required or authorized by law, including other purposes for which clients have provided consent.

It is the policy of Evermay to restrict access to and/or share all current and former clients’ information (i.e., information and records pertaining to personal background [including social security number and address], investment objectives, financial situation, financial planning issues, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated / nonaffiliated entities who need to know that information in furtherance of the client’s engagement ofEvermay.

Evermay shall disclose, as necessary, the client’s information:

(1) to affiliated entities and unaffiliated service providers and vendors in furtherance of establishing, maintaining, and reporting on the client’s Evermay relationship (i.e., Evermay Tax, broker-dealer, account custodian, record keeper, technology, performance reporting, customer relationship management software [CRM], proxy voting, insurance, independent managers, sub-advisers, etc.);

(2) required to do so by judicial or regulatory process; or

(3) otherwise permitted to do so in accordance with applicable federal and/or state privacy regulations.

However, Evermay does not, and shall not, disclose or share information with any affiliated or nonaffiliated persons, entities, or service providers for marketing or any other purposes or reasons not referenced above.

Below is a chart outlining the reasons we may share your information and whether the client may limit such information sharing.

To the extent U.S. Federal laws apply to client’s personal information, clients have the right to limit

(1) sharing for affiliates’ everyday business purposes—information about their creditworthiness,

(2) affiliates from using their information to market to them, and

(3) sharing for nonaffiliates to market to them.

(4) for other purposes required or authorized by law, including other purposes for which clients have provided consent.

IU.S. state laws and individual companies may give clients additional rights to limit sharing. To the extent permitted by the applicable laws of the jurisdiction, clients may request:

(1) to have client’s personal information corrected, for example, if it is incomplete or incorrect,

(2) to opt out of receiving marketing communications at any time or

(3) the right to file a complaint with an applicable government regulator such as a Data Protection Authority. To the extent clients are located in the European Economic Area (“EEA”) and the extent permitted by applicable law, clients may request:

(1) access to the personal information held by Evermay,

(2) the right to restrict or object to the processing of client’s personal information, or request that personal information is erased,

(3) the right to receive a copy of the personal information provided by Evermay in a structured, commonly used and machine-readable format,

(4) a copy of the personal information Evermay holds about clients provided to clients or another controller where technically feasible or

(5) where clients have provided personal information voluntarily, or otherwise consented to its use, the right to withdraw consent.

Evermay may transfer clients’ personal information obtained to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which client’s initially provided the information. To the extent required by applicable law, when Evermay transfers client’s information to recipients in other countries (such as the United States, United Kingdom, Ireland, or Cayman Islands), Evermay will protect that information as described in this Privacy Notice.

Please note that while attending meetings with Evermay, some team members use a digital assistant to take meeting notes. An Evermay representative can edit or remove information from the final notes. Potentially sensitive nonpublic personal information discussed during a meeting is not stored on the digital assistant platform, and is deleted after the notes are produced.

Evermay will endeavor to ensure clients’ personal information is kept accurate, complete, up to date, and relevant. Clients should notify Evermay if any information changes. If personal information is not accurate, complete, or up to date, please notify Evermay and the firm will take reasonable steps to ensure it is corrected. This Privacy Notice may change from time to time. Such changes shall be effective immediately upon notice. This Privacy Notice is for general guidance and does not constitute a contractor create legal rights and does not modify or amend any agreement Evermay has with clients.

ANY QUESTIONS OR CONCERNS:
Should you have any questions regarding the above, please contact Evermay’s Chief Compliance Officer.