Privacy Policy

Effective Date: January 1, 2025
Last Updated: January 1, 2025

1. Introduction

C137 Healthcare, LLC ("we," "us," or "our") is committed to protecting your privacy and safeguarding your personal and financial information. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use our website and financial advisory services.

As a independent insurance agency, we are subject to strict privacy regulations including the Gramm-Leach-Bliley Act (GLBA), SEC regulations, and state privacy laws.

2. Information We Collect

2.1 Personal Information

We collect personal information that you provide directly to us, including:

Name, address, email, and phone number
Date of birth and Social Security number
Employment and income information
Financial goals and investment objectives
Bank account and investment account information
Tax identification numbers
Beneficiary information for estate planning

2.2 Financial Information

Assets, liabilities, and net worth
Investment holdings and transaction history
Income sources and tax information
Risk tolerance and investment preferences
Credit information (when relevant to services)

2.3 Automatically Collected Information

When you visit our website, we automatically collect:

IP address and device information
Browser type and operating system
Pages viewed and time spent on our site
Referring website and navigation patterns
Cookies and similar tracking technologies

2.4 Communication Records

Email correspondence and chat transcripts
Phone call recordings (with your consent)
SMS message history (notification messages only)
Meeting notes and consultation records

3. How We Use Your Information

We use your information for the following purposes:

3.1 Providing Financial Services

Developing and implementing financial plans
Managing investment portfolios
Providing ongoing advisory services
Processing transactions and account changes
Preparing financial reports and statements

3.2 Communication and Notifications

Sending appointment reminders via SMS (notifications only)
Providing account alerts and security notifications
Responding to your inquiries and requests
Delivering market insights and educational content (with consent)

3.3 Compliance and Legal Obligations

Complying with SEC, FINRA, and state regulations
Meeting tax reporting requirements
Preventing fraud and money laundering
Responding to legal requests and court orders
Maintaining required regulatory records

3.4 Service Improvement

Analyzing website usage and user experience
Improving our services and offerings
Conducting internal research and development

4. How We Share Your Information

4.1 Service Providers

We may share your information with trusted third-party service providers who assist us in:

Custody and clearing services for your investments
Technology platforms and software providers
Professional services (attorneys, accountants, auditors)
Cloud storage and data processing
SMS notification services (for appointment reminders only)

All service providers are contractually obligated to protect your information and use it only for specified purposes.

4.2 Regulatory and Legal Disclosure

We may disclose your information when required by law or regulation:

To comply with SEC, FINRA, or state regulatory requests
To respond to subpoenas or court orders
To report suspicious activity or prevent fraud
To comply with tax reporting obligations

4.3 Business Transfers

If we are involved in a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections.

4.4 With Your Consent

We will share your information with other parties only with your explicit consent or at your direction.

5. SMS Notification Privacy - 10DLC Compliance

Important: We use SMS messaging exclusively for notifications, NOT for marketing or promotional purposes.

5.1 SMS Notification Types

Appointment reminders for scheduled consultations
Account alerts for important account activity
Security notifications for login attempts
Time-sensitive notifications requiring your attention

5.2 SMS Data Protection

Your phone number is used only for notification purposes
We do not share your mobile number with third parties for marketing
SMS messages are sent through 10DLC-compliant platforms
Message content is limited to necessary notification information
You can opt out at any time by replying STOP

5.3 Third-Party SMS Providers

We use reputable third-party SMS service providers who:

Comply with 10DLC regulations and TCPA requirements
Maintain appropriate security and privacy safeguards
Use your information only for delivering notification messages
Do not retain message content longer than necessary

6. Data Security

We implement comprehensive security measures to protect your information:

6.1 Technical Safeguards

256-bit SSL/TLS encryption for data transmission
AES-256 encryption for data at rest
Multi-factor authentication for account access
Regular security audits and penetration testing
Intrusion detection and prevention systems

6.2 Physical Safeguards

Secure data centers with restricted access
Surveillance and monitoring systems
Controlled access to physical records

6.3 Administrative Safeguards

Employee training on privacy and security
Background checks for all personnel
Access controls based on job responsibilities
Incident response and breach notification procedures

7. Your Privacy Rights

7.1 Access and Correction

You have the right to:

Access the personal information we hold about you
Request corrections to inaccurate information
Obtain copies of your records

7.2 Opt-Out Rights

Opt out of marketing emails (unsubscribe link provided)
Opt out of SMS notifications (reply STOP)
Request to be added to our do-not-call list
Limit certain information sharing (where permitted by law)

7.3 State-Specific Rights

Depending on your state of residence, you may have additional rights such as:

Right to deletion (California CCPA/CPRA)
Right to know what information is collected and shared
Right to non-discrimination for exercising privacy rights

8. Cookies and Tracking Technologies

We use cookies and similar technologies to:

Remember your preferences and settings
Analyze website traffic and usage patterns
Improve website functionality and user experience
Provide security features

You can control cookies through your browser settings, but disabling cookies may limit website functionality.

9. Data Retention

We retain your information for as long as:

You remain an active client
Required by SEC regulations (typically 6+ years after termination)
Necessary for legal, tax, or audit purposes
Needed to resolve disputes or enforce agreements

10. Children's Privacy

Our services are not directed to individuals under 18. We do not knowingly collect personal information from minors without parental consent.

11. International Data Transfers

Your information is primarily stored and processed in the United States. If you are located outside the U.S., your information will be transferred to and processed in the U.S., which may have different data protection laws.

12. Changes to This Privacy Policy

We may update this Privacy Policy periodically. We will notify you of material changes by:

Posting the updated policy on our website with a new "Last Updated" date
Sending email notifications for significant changes
Providing notice through our client portal

13. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us:

C137 Healthcare, LLC
Privacy Officer
Email: privacy@c137healthcare.com
Phone: (555) 137-CARE
Mail: C137 Healthcare Privacy Office [Address]

14. Regulatory Information

C137 Healthcare is a independent insurance agency with the Securities and Exchange Commission (SEC). Our complete Form ADV, including additional privacy disclosures, is available upon request and through the SEC's Investment Adviser Public Disclosure website (adviserinfo.sec.gov).

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