PRIVACY POLICY
Privé Wealth Management, LLC
Effective Date: 11/12/2025
OUR COMMITMENT TO PROTECTING YOUR PRIVACY
Privé Wealth Management, LLC ("Privé," "we," "our," or "us") is committed to safeguarding the
confidential information of our clients. We recognize that you have entrusted us with personal and
financial information, and we take seriously our obligation to keep that information secure and
confidential.
This Privacy Policy describes:
• What information we collect about you
• How we use that information
• Whether we disclose that information to anyone
• How we protect your information
• Our SMS/text messaging practices
We do not sell client information to third parties.
INFORMATION WE COLLECT
In the course of providing financial planning, investment advisory, and insurance services, we collect
"nonpublic personal information" about you. This includes:
Information You Provide to Us:
• Personal Identifying Information:
• Name, address, telephone number, email address
• Mobile phone number (if you opt into SMS communications)
• Social Security number or Tax Identification Number
• Date of birth
• Government-issued identification (driver's license, passport)
• Financial Information:
• Income and employment information
• Assets and liabilities
• Net worth
• Bank account information
• Credit card information (if used for fee payments)
• Investment account information
• Tax information
• Insurance policies
• Family and Personal Information:
• Marital status and family information
• Beneficiary designations
• Estate planning documents (wills, trusts, powers of attorney)
• Health information (if relevant to insurance or financial planning)
• Goals and Preferences:
• Investment objectives and risk tolerance
• Financial goals and concerns
• Time horizon
• Restrictions or preferences for investments
• Communication preferences (including SMS opt-in status)
Information We Receive from Your Transactions:
• Account balances and positions
• Transaction history (purchases, sales, deposits, withdrawals)
• Investment performance
• Fees paid
Information We Receive from Third Parties:
With your authorization, we may receive information from:
• Custodians holding your accounts (Charles Schwab & Co., Inc.)
• Your other professional advisers (accountants, attorneys, other financial advisers)
• Credit bureaus (if applicable)• Insurance carriers
• Employers (for retirement plan information)
• RingCentral (our communications service provider for phone and SMS services)
HOW WE USE YOUR INFORMATION
We use your information only for legitimate business purposes in connection with providing advisory
services, including:
• Providing Financial Advice:
• Analyzing your financial situation
• Developing financial plans and investment strategies
• Making investment recommendations
• Monitoring and managing your accounts
• Servicing Your Accounts:
• Processing transactions
• Calculating and billing fees
• Providing account statements and performance reports
• Responding to your inquiries
• Communicating with You:
• Sending appointment reminders (via email, phone, or SMS if you opt in)
• Providing account alerts and notifications (via email, phone, or SMS if you opt in)
• Responding to your questions and requests
• Sending important service announcements
• Complying with Legal Requirements:
• Verifying your identity (anti-money laundering compliance)
• Filing regulatory reports
• Responding to subpoenas or legal process
• Maintaining required books and records
• Operating Our Business:
• Managing risk
• Protecting against fraud
• Resolving disputes or complaints• Auditing and quality control
• Improving Our Services:
• Understanding client needs and preferences
• Developing new services
• Analyzing the effectiveness of our services
We do not use your information for unrelated marketing purposes or sell your information to
third parties.
SMS/TEXT MESSAGING TERMS AND CONDITIONS
Overview
We offer optional SMS (text message) communications to clients who wish to receive appointment
reminders, account alerts, and service notifications via text message. SMS communications are
provided through RingCentral, our communications service provider.
SMS communications are entirely optional.
You are not required to opt into SMS to receive our
advisory services. You may choose to communicate with us via email and phone calls only.
IMPORTANT: SMS opt-in consent and phone numbers provided for SMS purposes will NOT be
shared with third parties or affiliates for marketing purposes. Your mobile phone number is used
solely for delivering text messages from Privé Wealth Management and is shared only with RingCentral
(our SMS service provider) for the purpose of message delivery.
Opt-In Required
By providing your mobile phone number and opting into SMS communications (via web form, written
consent form, verbal consent during a conversation, or other medium), you are agreeing to receive
SMS messages from Privé Wealth Management.
We will never send you SMS messages without your prior express written or verbal consent.
Types of SMS Messages You May Receive
If you opt into SMS communications, you may receive the following types of messages:
• Appointment Reminders: Reminders of upcoming meetings and calls
• Account Alerts: Notifications about your investment accounts (if you request them)• Service Notifications: Important updates about our services or your account
• Security Codes: Two-factor authentication codes for secure account access
• Conversations: Text-based conversations between you and your adviser
• Internal Communications: Messages between Privé team members (if applicable to your service)
We do not send marketing or promotional messages via SMS unless you specifically opt into
marketing communications separately.
Message Frequency
Message frequency varies depending on your service needs and preferences. You may receive:
• Appointment reminders before scheduled meetings
• Account alerts as needed based on your notification preferences
• Occasional service announcements
• Responses to your text inquiries
You will not receive more than 10 messages per month unless unusual circumstances require
additional communications.
Costs and Fees
Message and data rates may apply. Standard text messaging rates from your mobile carrier will apply
to SMS messages sent and received. We do not charge additional fees for SMS communications, but
your wireless carrier may charge you according to your mobile plan.
We are not responsible for charges from your mobile carrier.
Supported Carriers
SMS services are available on most major U.S. mobile carriers, including but not limited to:
• AT&T;
• Verizon
• T-Mobile
• Sprint
• U.S. Cellular
• MetroPCS
• Boost Mobile
• Cricket Wireless
If you experience issues receiving messages, please contact your mobile carrier or contact us for
assistance.
Opt-Out Procedures
You may opt out of SMS communications at any time. To stop receiving text messages from us:
1. Reply STOP: Text the word "STOP" to any message you receive from us
2. Reply UNSUBSCRIBE: Text "UNSUBSCRIBE" to opt out
3. Contact Us: Call (470) 826-3211 or email peustache@privewealthmanagement.com
After you opt out:
• You will receive one final confirmation message
• You will no longer receive SMS messages from us
• Opting out of SMS will not affect your ability to receive our advisory services
• You will continue to receive communications via email and phone
• You may opt back in at any time by contacting us
Help and Support
For assistance with SMS communications:
• Text HELP: Reply "HELP" to any message for assistance
• Call Us: (470) 826-3211
• Email Us: peustache@privewealthmanagement.com
• Visit Our Website: www.privewealthmanagement.com
Security and Privacy of SMS Communications
Important Security Information:
• SMS is not encrypted: Text messages are not encrypted by mobile carriers and should not be
considered a secure form of communication
• No sensitive information via SMS: We will not send sensitive financial information, account
numbers, Social Security numbers, or passwords via text message
• Device security is your responsibility: You are responsible for securing your mobile device with a
passcode or biometric authentication
• Risk of interception: Text messages can potentially be intercepted or accessed by others who have
access to your phone
• Lost or stolen phones: If your phone is lost or stolen, immediately contact us to disable SMS
communications
What We Will and Won't Send via SMS:
■ We WILL send via SMS:
• Appointment reminders (date, time, general topic)
• General account alerts ("Your quarterly statement is available")
• Service announcements ("Our office will be closed on [date]")
• Two-factor authentication codes
• Responses to your non-sensitive questions
■ We WILL NOT send via SMS:
• Account numbers or balances
• Social Security numbers
• Passwords or security questions
• Detailed financial information
• Recommendations to buy or sell specific securities
• Sensitive personal information
For sensitive communications, we will use secure email, phone calls, or our secure client portal.
SMS Service Provider
SMS services are provided through RingCentral, our business communications platform. When you
opt into SMS, your mobile phone number is shared with RingCentral for the purpose of delivering text
messages. RingCentral is bound by its own privacy policy and terms of service.
RingCentral Information:
• RingCentral Privacy Policy: https://www.ringcentral.com/legal/privacy-notice.html
• RingCentral Terms of Service: https://www.ringcentral.com/legal.html
Consent and Agreement
By opting into SMS communications from Privé Wealth Management:
• You consent to receive SMS messages at the mobile number you provided
• You confirm that you are the owner or authorized user of the mobile number
• You agree to notify us if your mobile number changes
• You understand that message and data rates may apply
• You understand that SMS is not encrypted and carries security risks
• You understand you can opt out at any time by texting STOP• You agree to these SMS Terms and Conditions
Changes to SMS Terms
We may update these SMS Terms and Conditions from time to time. If we make material changes, we
will notify you via SMS or email. Your continued use of SMS services after changes indicates your
acceptance of the updated terms.
SHARING YOUR INFORMATION WITH THIRD PARTIES
We may share your information with third parties only as described below. We do not sell your
information.
Service Providers
We may disclose your information to companies that perform services on our behalf, including:
• Custodians: Charles Schwab & Co., Inc., which holds your investment accounts and executes
transactions
• Technology Providers: Companies that provide software, data storage, or other technology services
to us
• Communications Providers: RingCentral, which provides our phone and SMS services
• Professional Advisers: Our attorneys, accountants, or compliance consultants who assist us in
providing services or operating our business
• Third-Party Money Managers: Investment management firms that provide model portfolios or
sub-advisory services for your account
• Insurance Carriers: When you purchase insurance products, we share information necessary to
issue policies
When we share information with service providers, we:
• Share only the information necessary for them to provide their services
• Enter into agreements requiring them to protect the confidentiality of your information
• Prohibit them from using your information for their own marketing purposes
Other Disclosures
We may also disclose your information:
• At Your Direction: When you authorize us to share information (e.g., with your accountant or
attorney)
• To Protect Our Rights: To enforce our agreements, collect fees owed, or protect our legal rights
• As Required by Law: To comply with laws, regulations, court orders, subpoenas, or other legal
process
• To Regulatory Authorities: To respond to examinations or inquiries from securities regulators, state
insurance departments, or other authorities
• In Corporate Transactions: In the event of a merger, acquisition, or sale of our business (subject to
confidentiality protections)
What We Do NOT Do
We do NOT:
• Sell your information to third parties
• Share your information with unaffiliated third parties for their marketing purposes
• Share your information with affiliates for their marketing purposes (we have no affiliates)
Because we do not share your information for marketing purposes, you do not have a right to
"opt out" of such sharing.
HOW WE PROTECT YOUR INFORMATION
We maintain physical, electronic, and procedural safeguards to protect your information from
unauthorized access or use.
Physical Safeguards:
• Secure storage of paper records in locked cabinets
• Controlled access to our office
• Secure disposal of records (shredding) when no longer needed
• Building security measures
Electronic Safeguards:
• Firewall protection and antivirus software
• Encryption of sensitive data (both stored data and data in transit)
• Strong password policies and authentication• Secure email for transmission of sensitive information
• Regular software updates and security patches
• Secure Wi-Fi networks with encryption
• Multi-factor authentication where available
• Device encryption for laptops, phones, and tablets
• Regular data backups
• Secure cloud storage with reputable providers
• Encrypted SMS communications where available through RingCentral
Procedural Safeguards:
• Access to client information limited to personnel who need it to provide services
• Confidentiality agreements signed by all personnel
• Regular training on data security and privacy
• Written information security policies
• Vendor due diligence and oversight
• Incident response procedures
• Regular review and updating of security measures
Your Role in Protecting Your Information:
While we take extensive measures to protect your information, you also play an important role:
• Protect Your Passwords: Use strong passwords for your custodian accounts and online portals; do
not share passwords
• Secure Your Mobile Device: Use a passcode or biometric lock on your phone; enable remote wipe
capability
• Be Cautious with Communications: Do not send sensitive information via unencrypted email or
SMS; use secure methods we provide
• Verify Communications: Be suspicious of emails, calls, or texts claiming to be from us or your
custodian asking for sensitive information; verify by calling us directly
• Review Statements: Regularly review your account statements for unauthorized activity
• Report Suspicious Activity: Immediately report any suspected security incidents or fraudulent
activity
• Use Secure Networks: Avoid accessing financial accounts on public Wi-Fi networks
• Keep Software Updated: Ensure your devices have the latest security updates
DATA BREACH NOTIFICATION
In the unlikely event that your information is compromised in a data breach, we will notify you as
promptly as possible. Our notification will include:
• Description of what happened
• Types of information that were compromised
• Steps we have taken to address the breach
• Steps you should take to protect yourself
• How to contact us with questions
We will also notify appropriate regulatory authorities and law enforcement as required by law.
YOUR RIGHTS AND CHOICES
You have the right to:
• Access Your Information: Request to see the personal information we have about you
• Correct Your Information: Request that we correct inaccurate information
• Limit Information Sharing: While we do not share your information for marketing purposes (so there
is no opt-out right), you may limit our sharing with service providers in some circumstances, though this
may limit our ability to provide services
• Opt Out of SMS: You may opt out of SMS communications at any time by texting STOP or contacting
us
• Close Your Account: Terminate our advisory relationship at any time as provided in your advisory
agreement
To exercise these rights, please contact us using the information at the end of this notice.
INFORMATION ABOUT FORMER CLIENTS
If you close your account or terminate our advisory relationship, we will continue to protect your
information as described in this Privacy Policy. We retain information about former clients as required
by law and regulation (typically for at least 6 years) and continue to safeguard it according to our
information security policies.
We do not share information about former clients except as permitted for current clients (to service
providers, as required by law, etc.).
SPECIAL NOTICE FOR CALIFORNIA RESIDENTS
If you are a California resident, you have additional rights under the California Consumer Privacy Act
(CCPA):
• Right to know what personal information we collect, use, and share
• Right to request deletion of your personal information (subject to exceptions for information needed to
provide services or comply with legal obligations)
• Right to opt out of "sale" of personal information (note: we do not sell personal information)
• Right to non-discrimination for exercising your privacy rights
To exercise these rights, please contact us using the information below.
California Notice at Collection:
We collect the categories of personal information described in this Privacy Policy for the business
purposes described. We do not sell personal information.
SPECIAL NOTICE FOR INSURANCE CUSTOMERS
For clients to whom we provide insurance services, this Privacy Policy also serves as the insurance
privacy notice required by Georgia insurance regulations.
When you purchase insurance products through us, we share information with insurance carriers as
necessary to apply for and service policies. Insurance carriers have their own privacy policies
governing their use of your information, and you should review those policies.
CHILDREN'S PRIVACY
Our services are not directed to individuals under the age of 18. We do not knowingly collect personal
information from children. If you are a parent or guardian and believe we have collected information
about a child, please contact us.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to modify this Privacy Policy at any time. If we make material changes, we will
provide you with a revised Privacy Policy and, if required by law, seek your consent.
We will provide an updated Privacy Policy:
• When we make material changes
• At least annually (if required based on our information sharing practices)
• Upon request
QUESTIONS OR COMPLAINTS
If you have questions about this Privacy Policy or concerns about our privacy practices, please contact
us:
Privé Wealth Management, LLC
Philippe-Joseph Eustache, Chief Compliance Officer
1702 Sweet Barley Way
Grayson, GA 30017
Phone: (470) 826-3211
Email: peustache@privewealthmanagement.com
Website: www.privewealthmanagement.com
We will respond to your inquiry promptly.
If you believe we have violated your privacy rights or have a complaint about our privacy practices, you
may also contact:
Georgia Securities Division
2 Martin Luther King Jr. Drive SE, Suite 802, West Tower
Atlanta, GA 30334
Phone: (404) 656-3920
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Phone: (202) 551-6551
Website: www.sec.gov
Georgia Department of Insurance (for insurance-related complaints)
2 Martin Luther King Jr. Drive, Suite 704, West Tower
Atlanta, GA 30334
Phone: (404) 656-2070
ANNUAL PRIVACY NOTICE DELIVERY
We provide this Privacy Policy to all clients:
• When you first become a client
• Annually, if required based on our information sharing practices (currently, annual delivery is not
required because we do not share information for marketing purposes)
• When we make material changes to the policy
• Upon request at any time
You may request a copy of this Privacy Policy at any time by contacting us at the phone number
or email address above.
Effective Date: 11/12/2025
Last Reviewed: 11/12/2025