Privacy Policy

Here at Aldrich Services LLP and our affiliates and subsidiaries, including but not limited to Aldrich Capital Advisors LP, Aldrich CPAs + Advisors LLP,  Aldrich Wealth LP, Aldrich Solutions LLC, and Pacific Coast Capital LLC (collectively, “Aldrich, ” “Aldrich Advisors,” “we,” “us,” or “our”), we take protecting your personal information very seriously. This Privacy Statement explains how we may collect, use and disclose your personal information.

Personal Information

In the course of offering and providing our products and services, it is common for us to receive personal information from and about our clients, including financial and business information. Generally, personal information is any information that can be used, directly or indirectly, to identify, locate, or contact someone. The categories of personal information we may collect, or process can include the following:

Identifiers (e.g., names, physical addresses, mailing addresses, email addresses, phone numbers, IP addresses, and account usernames).

Geolocation Data (e.g., approximate location from IP address).

Internet or Similar Network activity (e.g., browsing history, search history, information on your interaction with a website, application or advertisement).

Commercial Information (e.g., records of personal property, products or services purchased, obtained or considered or other purchasing or consuming histories or tendencies.)

Inferences Drawn (e.g., information, data, assumptions, or conclusions derived from facts, evidence, or another source of information or data reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes).

Sensitive Data (e.g., racial or ethnic background, national origin, mental or physical health conditions or diagnoses, citizenship or immigration status, genetic or biometric data, or sexual orientation).

Sensory Data (e.g., audio, electronic, visual, thermal, olfactory information).

Customer Records and Financial Information (e.g., bank account numbers, social security numbers, driver’s license numbers, signatures, employment information, and other financial information)

Personal information does not include:

  1. Publicly available information, such as information obtained from government records, widely distributed media, or information we reasonably believe you made available to the public or have not restricted to a specific audience.
  2. Deidentified personal information we maintain in deidentified form and do not attempt to reidentify except as required or permitted by law;
  3. Information covered by other laws, such as:
    1. health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA)
    2. personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the Driver’s Privacy Protection Act of 1994, and the Family Educational Rights and Privacy Act.

How We Collect Personal Information

We receive the majority of personal information directly from our clients or their agents in the course of performing our services. For example, clients may provide their personal information to us in order for us to prepare tax returns, provide tax consultation, perform financial audits or providing investment advice. We may also collect personal information through services authorized by our clients.

We do collect some personal information through our website (www.aldrichadvisors.com). For example, if you set up an account for client portal access on our website, we will collect information such as your name, email address, username, and password, and we will receive any documents you submit through the client portal. If you fill out our “Contact Us” form or register for a webinar or event through our website, we will collect your name, email address, and phone number. Our web servers may also collect information from visitors such as IP address, browser type and version, time zone setting, operating system and platform. Some web browsers allow the user to send “do-not-track” signals to websites, but our website does not respond to those signals.

Our website, like most websites, employs “cookies” and similar technologies. Cookies are small files that are stored on your computer or mobile device when you visit our website and allow us to recognize your browser and obtain information about your use of our website

How We Use Personal Information

We use the personal information we collect from you for the following business and commercial purposes:

Deliver Services You Request (e.g,, fulfill or meet the reason for which the information is provided, carrying out our obligations arising from any contracts entered, and enforce our rights for billing and collections).

Respond to Inquiries from You (e.g,, provide information you request, enlist you in seminars or other programs you request to attend).

Providing and Operating our Website (i.e., maintaining functionality, troubleshooting, debugging, identify and repair errors, and improving performance).

Marketing and Communications (e.g., newsletters, event invitations, educational information that may be of interest to you, sharing firm news and updates, determining what services and products you may be interested in)

Analytics and Measurement (e.g., understanding website usage, improving content provided to you, analysis and internal research for product/services development).

Recruiting and Hiring (e.g., processing applications and communicating with applicants).

Security and Fraud Detection and Prevention (e.g., protecting our website and our systems, detecting security incidents, and protecting against malicious, deceptive, fraudulent, or illegal activity).

Corporate Transactions (e.g., advance our commercial or economic interests,

Legal Obligations (i.e., complying with state and federal laws and government compliance obligations)

Disclosure of Personal Information to Third Parties for Business or Commercial Purpose

We may disclose your personal information to the following categories of third parties:

Web and Analytics Providers.  This may include third-party tracking technology, cookie, and pixel operators on our website, which collect and use personal data to analyze the use, performance, and effectiveness of our services, communications, and marketing.

Digital Marketing Providers.  This may include third parties that facilitate the delivery of our online advertisements, promotions and offers.

Categories of Personal Data We Disclose to Third Parties and Third Parties’ Business or Commercial Purpose for Processing Personal Data

Categories of Personal Data

The Business or Commercial Purpose(s) for which the Personal Data may be processed by Third Parties.

The Categories of Third Parties with whom we may disclose Personal Data

Identifiers.

·      Advertising And Marketing Services

·      Commercial And Economic Interests

·      Web/Data Analytics Providers

·      Advertising/Marketing Providers

·      Service Providers

Commercial information.

·      Advertising And Marketing Services

·      Commercial And Economic Interests

·      Web and Data Analytics Providers

·      Digital Marketing Providers

·      Financial And Payment Technology Providers

Internet or other similar network activity.

·      Advertising And Marketing Services

·      Commercial And Economic Interests

·      Web And Data Analytics Providers

·      Digital Marketing Providers

Audio, electronic, visual, thermal, olfactory, or similar information.

·      Advertising And Marketing Services

·      Commercial And Economic Interests

·      Web And Data Analytics Providers

·      Digital Marketing Providers

·      Financial And Payment Technology Providers

Inferences drawn from other personal data.

·      Advertising And Marketing Services

·      Commercial And Economic Interests

·      Web And Data Analytics Providers

·      Digital Marketing Providers

·      Financial And Payment Technology Providers

WE DO NOT SELL OR OTHERWISE SHARE PERSONAL INFORMATION WITH THIRD PARTIES FOR DIRECT MARKETING PURPOSES.b

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access and disclosure. We maintain physical, electronic and procedural safeguards to limit access to your nonpublic personal information.

Unfortunately, transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to us through our website or other electronic means. Any electronic transmission of personal information is at your own risk.

Embedded or Linked Third Party Applications and Services

Some applications and services embedded within, or linked from, our website, such as maps and social media platforms, are controlled by third-party providers. These third parties may use cookies, alone or in conjunction with other tracking technologies, to collect information about you when you use our website or navigate away from our website. These third parties may also have privacy policies that differ from ours. For example, they may collect personal information about your online activities over time and across different websites, and other online services, and may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties or their privacy practices, and this Privacy Statement does not apply to any third-party website or service you may access through our website. If you have any questions about a third-party provider’s privacy policies or advertising, you should contact the responsible provider directly.

Your Privacy Rights

Subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

  1. Confirmation and Access.  Request confirmation whether we process or have processed your personal data and if so, inform you of the categories of personal data we process or have processed about you. Request a copy of the personal data we process or have processed about you and a list of third parties to whom we have disclosed your personal data, if any.
  2. Request deletion of your personal data we collect and retain.
  3. Request us to correct inaccurate personal data that we maintain about you.

To exercise any of the rights you may have as described above, you may submit a request by clicking here and completing our request form or by contacting us at (503) 620-4489. Only you or your authorized agent may make an authenticated request to exercise your rights. If you use an authorized agent to submit an authenticated request on your behalf, you will be required to provide additional information as described below.

To authenticate your identity to process your request, we will request your full name, street address, city, zip code, phone number, and email address. For us to treat your request as an authenticated request, you must (i) provide sufficient information, commensurate with the type or sensitivity of the information you are requesting, that allows us to reasonably authenticate you are the person about whom we may have collected personal information (or an authorized representative of that person); and (ii) describe your request with sufficient detail to allow us to properly understand, evaluate and respond to you. 

We endeavor to respond to an authenticated request within 45 days of its receipt. If we require more time to respond, we will inform you of the reason and extension (up to an additional 45 days) in writing.  If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of the authenticated request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable.

If your request is for information beyond the 12-month period or you make a second request, we reserve the right to charge a reasonable administrative fee to process or respond to such an authenticated request. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

For the following reasons, we may deny a request made under this section:

  1. We cannot authenticate the request;
  2. Retaining your personal information is reasonably necessary for us to:
  3. complete services or a transaction you requested for which we collected the personal information, take actions reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform our contract with you; or
  4. help ensure security and integrity of our systems; or
  5. preventing, detecting, protecting against or responding to and investigating, report or prosecuting person responsible for, security incidents, malicious, deceptive, fraudulent, or illegal activity; or
  6. debug systems to identify and repair errors that impair existing or intended functionality; or
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; or
  8. Comply with a legal obligation; or
  9. Make other internal and lawful uses of the personal data that are compatible with the purposes for which we collected and processed it and are and disclosed in this Privacy Statement.

Appealing a Denial Decision. If we have denied your request to exercise your rights, you may appeal our denial by submitting your appeal here.  

Changes to Our Privacy Statement

We have the right to amend this Privacy Statement at our discretion and at any time. If we make material changes to this Privacy Statement, we will post the updated Privacy Statement on our website and update the effective date.

Contact Information

Aldrich appreciates your business. If you have questions or comments about this Privacy Statement, please call your Aldrich contact or fill out this form.

California Residents

FOR CALIFORNIA RESIDENTS:

In addition to the information and rights described in Aldrich’s Privacy Statement, California law may provide you with additional rights regarding your personal information and our collection and use of your personal information. To learn more about your privacy rights under California law, visit here

PRIVACY STATEMENT-CALIFORNIA

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of Aldrich Services LLP and its subsidiaries and affiliates including but not limited to Aldrich Capital Advisors LP, Aldrich CPAs + Advisors LLP, Aldrich Wealth LP and Pacific Coast Capital LLC (collectively, “Aldrich Group” “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal Information Covered by the CCPA

Under the CCPA, personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. It does NOT include publicly available information or information that has been aggregated or de-identified.

The categories of personal information we may collect are described in our General Privacy Statement – click here

We obtain the categories of personal information from the following categories of sources:

  1. Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
  2. Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
  3. Directly and indirectly from activity on our website (www.aldrichadvisors.com). For example, submissions through our website portal or website usage details that are collected automatically.
  4. From third parties that interact with us in connection with the services we perform. For example, government agencies, and preparation of readiness assessments for projects that receive government funding.

Personal information does not include:

  1. Publicly available information from government records.
  2. De-identified or aggregated consumer information.
  3. Information excluded from the CCPA’s scope, like:
    1. health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    2. personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  1. Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
  2. Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
  3. Directly and indirectly from activity on our website (www.aldrichadvisors.com). For example, from submissions through our website portal or website usage details collected automatically.
  4. From third-parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.

Use and Sharing of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes as defined in Cal. Civ. Code § 1798.130(e):

(1)        Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

(2)        Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.

(3)        Debugging to identify and repair errors that impair existing intended functionality.

(4)        Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.

(5)        Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.

(6)        Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer provided that, for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out consumers that the service provider or contractor receives from, or on behalf of, the business with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with consumers.

(7)        Undertaking internal research for technological development and demonstration.

(8)        Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. 

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category of Personal Information

To Whom Shared

A. Identifiers

Affiliates; Service Providers; Contractors

B. Personal information categories listed in Cal. Civ. Code § 1798.80(e).

Affiliates; Service Providers;

C. Protected classification characteristics under California or federal law.

Affiliates; Service Providers;

F. Internet or other similar network activity.

Affiliates; Service Providers; Contractors

I. Professional or employment-related information.

Affiliates; Service Providers; Contractors

L. Sensitive Personal Information

Affiliates; Service Providers



We disclose your personal information for a business purpose to the following categories of third parties:

  1. Our affiliates.
  2. Service providers.
  3. Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. 

Access to Specific Information and Data Portability Rights

    1. You have the right to request details regarding the information we collect and share about you. information. Once we receive and confirm your verifiable consumer request, we will disclose to you:

      1. The categories of personal information we collected about you.
      2. The categories of sources for the personal information we collected about you.
      3. Our business or commercial purpose for collecting or selling that personal information.
      4. The categories of third parties with whom we share that personal information.
      5. The specific pieces of personal information we collected about you (also called a data portability request).
      6. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
        1. sales, identifying the personal information categories that each category of recipient purchased; and
        2. disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for this purpose.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the ability to complete such research if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information.
  8. Comply with a legal obligation.

Right to Correct Inaccuracies

If you believe that we maintain inaccurate personal information about you, you have the right to request that we correct your personal information.

Exercising Your Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  1. Calling us at (877) 620-4489.
  2. Form

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  1. Deny you goods or services.
  2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  3. Provide you a different level or quality of goods or services.
  4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (877) 620-4489

Form

Website: aldrichadvisors.com

Postal Address:

Aldrich Advisors

Attn: Legal

5665 Meadows Road, #200

Lake Oswego, OR 97035

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