Privacy Policy Notice

Introduction

Lumiere Financial Group LLC has adopted this Privacy Policy Notice in recognition of the importance of protecting the privacy and security of the personal information we obtain about our customers. We understand that you expect us to service you in an accurate and efficient manner. To do so, we collect and maintain certain nonpublic personal information about you ("Customer Information"). This notice describes the information we collect, how we use and disclose that information, and the measures we take to safeguard it.

Information We Collect

We collect certain nonpublic personal information about you in order to provide advisory and related services to you. Customer Information we collect may include:

• Information you provide on applications, questionnaires, subscription documents, or other forms. This may include personal and household information such as income, spending habits, investment objectives, financial goals, statements of account, records concerning your financial condition and assets, information concerning employee benefits and retirement plan interests, wills, trusts, mortgages, and tax returns.
• Identifying information such as your name, age, address, telephone number, email address, Social Security number, taxpayer identification number, date of birth, and other similar information.
• Information about your transactions with us or with others, such as broker-dealers, custodians, clearing firms, administrators, or other investment sponsors you select.
• Information we receive from consumer reporting agencies, such as credit bureaus, as well as other information and materials we may use to evaluate a service request or provide an appropriate recommendation.

Security of Your Information

We restrict access to Customer Information to those employees, officers, representatives, and service providers who need to know that information in order to service your account or carry out our business functions. We maintain physical, electronic, and procedural safeguards designed to protect your Customer Information and to comply with applicable federal and state standards.

Our Use of Artificial Intelligence

We may use certain third-party technology tools that incorporate artificial intelligence ("AI") to support limited internal business, administrative, and productivity functions, such as assisting with note-taking, summarizing information, organizing internal records, and drafting or reviewing routine communications.

To the extent reasonably necessary for these limited purposes, certain Customer Information and other nonpublic personal information that you provide to us may be processed through these tools. We use such tools solely to assist our personnel in performing administrative and operational functions.

We require providers of these tools to be subject to contractual confidentiality, data protection, and use-restriction obligations designed to protect Customer Information in a manner consistent with applicable law. We do not permit such providers to use Customer Information to train general artificial intelligence models or for any purpose other than providing services to us, except as necessary to maintain or secure their services or as otherwise required by law.

Information We Disclose

We do not disclose the nonpublic personal information we collect about our customers to anyone except as permitted or required by law, including in the following circumstances:

1. In furtherance of our business relationship with you, and only to those persons or entities necessary to effect transactions or provide authorized services on your behalf, such as broker-dealers, custodians, clearing firms, administrators, or independent managers.
2. To service providers and other third parties that perform administrative, operational, technological, compliance, or other support services on our behalf, provided that such parties are subject to appropriate obligations regarding the confidentiality and permitted use of the information.
3. To persons assessing our compliance with industry standards, or legal and regulatory requirements, such as professional licensing authorities, consultants, examiners, and similar parties.
4. To our attorneys, accountants, auditors, and other professional advisers.
5. To governmental agencies, regulators, courts, or other third parties, as otherwise permitted or required by law.

Where we disclose Customer Information to nonaffiliated third parties as permitted by law, we require those parties to use the information only for the purposes for which it was disclosed and not for unauthorized purposes.

We do not share, sell, or provide your mobile phone number or messaging consent data to third parties or affiliates for marketing or promotional purposes.

Former Clients

If you decide to close your account(s) or otherwise become an inactive customer, we will continue to adhere to the privacy policies and practices described in this notice, as amended from time to time and as permitted by law.

Changes to Our Privacy Policy

In the event there is a material change to our privacy policies or practices regarding how we collect, use, or disclose your Customer Information, we will provide notice to you as required by applicable law. Where applicable, you will be given an opportunity to limit or opt out of certain disclosure arrangements.

Questions

If you have questions about this Privacy Policy Notice or about the privacy of your Customer Information, please call our main number at (212) 516-5900 and ask to speak to the Chief Compliance Officer.