Legal & Privacy

PRIVACY STATEMENT OF ALTFEST PERSONAL WEALTH MANAGEMENT

The purpose of this privacy policy is to explain to you Altfest Personal Wealth Management’s (“we,” “our,” or “us”) specific practices regarding our use of information about you that you provide to us and information we collect about you from other sources. This policy is also intended to meet our privacy obligations to you under applicable privacy laws, including the Gramm-Leach-Bliley Act (“GLBA”) and Securities and Exchange Commission’s Regulation S-P (“Regulation S-P), as well as comply with any obligations we may have under state law and under the European Union’s General Data Protection Regulation (“GDPR”). This policy, which becomes effective on December 1^st, 2019, applies to our processing of personal data about you—our customers, potential customers, and visitors to our website.

Generally speaking, the GLBA and Regulation S-P require that investment advisers such as Altfest Personal Wealth Management limit their use of certain nonpublic personal information they may learn about you, such as your name, occupation and financial history. In addition, state laws and the GDPR may further limit our use of your personal information and provide you with certain rights, depending on where you are a resident. As a registered investment adviser, we are required to provide our clients with an annual notice describing our privacy policies and practices. The policies described below apply both to current clients and to individuals who no longer have a relationship with us.

For purposes of the GDPR and any other applicable data privacy laws, Altfest Personal Wealth Management is considered to be the data controller. This means we are responsible for making decisions about how and why your personal data is processed, and we are responsible for ensuring that it is used in accordance with applicable data protection laws.

We are very aware of the sensitivity of such information and provide access to it only when necessary in the course of our activities directly on your behalf.

I. THE INFORMATION WE COLLECT, THE PURPOSES FOR WHICH WE COLLECT IT, AND OUR LAWFUL BASES FOR PROCESSING YOUR INFORMATION:

We will typically collect personal data directly from you, although in some cases we may obtain your personal information from third parties, such as your lawyers and accountants, as well as government agencies and third parties who provide services to us. We may also collect personal information about you through your interactions with our information technology resources. In all cases, we will collect personal information about you in accordance with the principles outlined in this policy and applicable law. Our lawful basis for processing your data may vary depending on the jurisdiction in which you reside.

The table below summarizes the information we collect about you and/or your household, our purpose for collecting it, and our lawful basis for processing it.

Information we collect:	Our purpose for collecting this information:	Our lawful basis for processing this information:
Information we receive from you on applications, contracts, and other forms, such as your name, address, your social security number, your asset level, your employment history, and your income level.	We use this information to provide our wealth management services to you.	Necessary to enter into or perform a contract with you.
Information about your transactions with us, our affiliates, and others, including your transaction and purchase history.	We use this information to provide our wealth management services to you.	Necessary to enter into or perform a contract with you.
Your tax, financial, and legal information from your accountants and attorneys.	We use this information to provide our wealth management services to you.	Necessary to enter into or perform a contract with you.
Information we collect automatically when you visit our website or access our services through a mobile application, such as your IP address, device type, unique device identification numbers, browser-type, time zone settings, your geolocation, and your browsing history. Some of this information may be collected using cookies and similar tracking technology, which we explain more below.	We use this information to diagnose problems with our computers and to maintain and improve our website. We may also log a file of IP addresses to gauge overall usage, traffic, and performance of our website. We do not use IP addresses or have the ability to use IP addresses to personally identify users or track the usage patterns of individual users.	Necessary for our legitimate interests (maintain the security of our computer systems, administer our website, etc.).

We do not collect any sensitive or special category information about you without your consent, such as details about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic information, and biometric information. We also do not collect information about criminal convictions and offenses.

II. CATEGORIES OF INFORMATION WE DISCLOSE FOR BUSINESS PURPOSES:

In general, the information we collect is used to provide you with the services you have requested in the manner you have requested them. For example, we at Altfest Personal Wealth Management may provide others the following kinds of nonpublic personal information which is required in the course of our normal business operations:

Information we receive from you on applications or other forms such as your name, your address, your social security number, your asset level and/or your income
Information about your transactions with us, our affiliates, and others including your purchase history and the date and time at which you made those purchases.

III. CATEGORIES OF THIRD PARTIES TO WHOM WE DISCLOSE YOUR INFORMATION:

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

Financial service providers such as Charles Schwab, TD Ameritrade, and other brokers, in order to buy securities on your behalf and manage private partnerships you invest in. These service providers are contractually prohibited from disclosing or using this information for any purpose other than for which it was disclosed.
Outside custodians, broker/dealers; and other financial service providers, with your permission.
Your attorneys and accountants, with your permission.
Other nonaffiliated entities when we believe such disclosure is required to respond to a court order, subpoena, or in the course of a legal proceeding, or as otherwise permitted by law.

IV. WE DO NOT SELL YOUR PERSONAL INFORMATION

While we may use the information we collect for purposes of marketing our own services to you, we do not sell any of your personal information and have not done so in the last 12 months. We have no intention of doing this in the future. We also do not share your nonpublic personal information with nonaffiliated companies so that they may market their products or services to you or engage in joint marketing with us. We have no intention of doing this in the future.

V. DATA RETENTION POLICY

We store your personal information on computer systems in the United States operated by or under the supervision of Altfest Wealth Management, our affiliates, or our service providers.

We will maintain personal data about you for as long as necessary in connection with both our and your legal rights and obligations for the purposes for which it was collected, to defend or advance legal claims, or as otherwise required by applicable law. We will delete your personal information at your request (where such request conforms to the relevant legal requirements and is not otherwise limited); and in any case, upon our discretion and expiration of the maximum storage term set forth by applicable law.

VI. CHILDREN’S PRIVACY

Our services are not intended for individuals under 18 years of age, and we do not knowingly collect personal information from individuals under the age of 18.

VII. COOKIE POLICY

While you are on-line, your computer saves so-called “cookies.” These are small files that control how our website is displayed and operates. Cookies do not damage your computer and do not contain viruses. Cookies serve to make our website more user-friendly, effective and secure.

Most of the cookies we use are “session cookies,” which are automatically deleted as soon as you leave the site. Other cookies, called “permissive cookies,” remain on your computer until you delete them. Such cookies allow us to recognize your browser the next time you visit, and the browser settings let previously viewed pages load faster, for example. We use cookies to offer you the best possible experience on our website. We therefore save them and analyze their data – although they do not identify you personally. This improves the usefulness of our website. We perform anonymous statistical analyses of our internet presence, and do not identify you personally.

You can change your browser settings so that you are notified when cookies are being used, and you can allow them only once, or refuse them in certain cases or completely. You may also activate the automatic deletion of cookies when you close your browser. Deactivating cookies may restrict website functionality.

When you access our website or services through a third party’s website, that website may use cookies or similar technologies to collect data about user behavior for its own purposes. The use of cookies is conducted as described in the third party’s own cookie policy, over which we have no control.

Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our services do not currently respond to browser DNT signals. For more information on DNT, see https://allaboutdnt.com/.

VIII. BUSINESS TRANSFERS

If there is a change of control in Altfest Personal Wealth Management’s business, our client information could be transferred as part of that transaction and your nonpublic personal information could potentially be transferred. However, if the privacy statement materially changes this privacy statement or the information-handling practices described herein, such changes will be described to you, and we will provide you with any rights you may have under applicable law.

IX. THIRD PARTIES

You may be able to access third parties’ websites through our website, or they may provide services through our website. We are not responsible for the privacy practices of those third parties, and you should refer to their privacy policies to learn how they collect and use your information.

X. YOUR RIGHTS

Under the GLBA, if you prefer that we not disclose nonpublic personal information about you to nonaffiliated third parties, you may opt out of those disclosures; that is, you may direct us not to make those disclosures. However, we only disclose your information with discretion and in the cases that we believe that it is necessary and to your advantage. We do not think that opting out is to your benefit in that it may interfere with how we conduct routine business matters on your behalf. If you wish to opt out of disclosures to nonaffiliated third parties or if you have any questions about our rules on our privacy policy, you may contact us using the information in the “Contact Us” section below.

You may, if you wish, request that we send you a summary of the information we have collected about you, and you may seek correction of information you believe to be inaccurate.

Whenever we collect and/or disclose information pursuant to your consent, you have the right to withdraw your consent at any time, except to the extent to which we have relied upon it or if your right to withdraw is otherwise limited by law.

Depending on your jurisdiction of residence, and depending upon whether the information was collected, processed, sold, or disclosed pursuant to the GLBA, you may also have the following rights available to you:

The right to access to your personal information (note that we must be able to verify your identity);
The right to restrict the processing of your personal information;
The right to object to our processing of your personal information (including for any processing for direct marketing purposes), when the processing is based on our legitimate interests;
The right to update and/or correct inaccurate personal information;
The right to request that we delete your personal information under certain circumstances;
The right to opt-out of the sale of your personal data to third parties (note that we do not engage in this practice); and
The right to request portability, which means receiving a machine readable copy of your personal data.

We will not discriminate against you in any way for exercising your rights.

XI. CONFIDENTIALITY AND SECURITY

We at Altfest Personal Wealth Management restrict access to nonpublic personal information about you to our employees who need to know that information. We maintain physical, electronic and procedural safeguards that comply with federal standards to safeguard your nonpublic personal information. Notwithstanding these security measures that we use to help protect your nonpublic personal information, no electronic data transmission or storage of information can be guaranteed to be secure. Please note that we cannot ensure or warrant the security of any information you provide to us.

XII. HOW TO HELP PROTECT YOUR INFORMATION

Because you, too, play a role in protecting your non-public personal information, we recommend that you do not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited e-mail. When using the password-protected area of our web site, remember to sign out of your account and close your browser window when you have finished your service. This is to help ensure that others cannot access your non-public personal information if you share a computer with someone else or are using a computer in a public place where others may have access to it.

XIII. CHANGES

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will notify you prior to the change becoming effective and provide you with any rights you may have under applicable law.

XIV. CONTACT US

If you have any questions about this privacy policy or wish to exercise any rights available to you, including the right to opt-out, please contact us through our website at www.altfest.com; email us at inquiry@altfest.com or contact us at 212-406-0850.

Dates of Lew Altfest’s awards listed in bio:

“Best Financial Advisers” in the country – Barron’s 2007, 2008, 2009, 2010, 2011, 2013, 2014, 2015, 2016, 2017; Money 1987; Worth 2008; Mutual Funds 2002; Medical Economics 1998, 2000, 2002, 2004, 2006, 2008, 2010, 2011, 2012, 2013; and Dental Practice 2011, 2012, 2013 magazines.

Lew Altfest Answers Almost All Your Questions About Money named one of the best financial planning books – Money magazine 1994

Dates of Karen Altfest’s awards listed in bio:

Lew Altfest Answers Almost All Your Questions About Money named one of the best financial planning books – Money magazine 1994

One of the “Best Financial Advisers” in the United States – Worth magazine 1996, 1997, 1998

One of the “120 Best Financial Advisers” – Medical Economics magazine, June 2000

“Planner of the Month” – Mutual Funds magazine, June 2002

One of “100 Top Advisors” – Mutual Funds magazine, September 2002

Disclosure Regarding Awards:

* InvestmentNews’ 40 Under 40 recipients are selected after a review of key criteria editorial staff have used to weigh the average 1,000 nominations received each of this project’s five years, including accomplishment to date, contribution to the industry, leadership and promise. There is no fee to participate in the ranking.

*Forbes’ Top Women Wealth Advisors developed by SHOOK Research, is based on an algorithm of qualitative and quantitative data, rating thousands of advisors with a minimum of seven years of experience & weighing factors like revenue trends, AUM, compliance records, industry experience and best practices learned through telephone and in-person interviews. Portfolio performance is not a criteria due to varying client objectives and lack of audited data. There is no fee to participate.

*Forbes’ Best-In-State Wealth Advisors, developed by SHOOK Research, is based on an algorithm of qualitative criteria, mostly gained via phone and in-person due diligence interviews, and quantitative data. Advisors who are considered have a minimum experience of seven years. The algorithm weights factors like revenue trends, assets under management, compliance records, industry experience and those that encompass best practices in their business and in their approach to working with clients. Portfolio performance is not a criteria due to varying client objectives and lack of audited data. There is no fee to participate.

*Barron’s America’s Top 100 Independent Financial Advisors is based on assets under management, revenue generated by advisors for their firm, and the quality of the advisors’ practices. Investment performance is not an explicit criterion because performance is often a function of each client’s appetite for risk. In evaluating advisors, they examine regulatory records, internal company documents, and 100-plus points of data provided by the advisors. There is no fee to participate. Additional details regarding the criteria and process utilized in formulating these rankings can be found by at http://www.barrons-conferences.com/advisor-rankings.html

*Barron’s state-by-state listing of America’s Top 1,200 Financial Advisors lists the top advisors in each state, with the number of ranking spots determined by each state’s population and wealth. The rankings are based on assets under management, revenue generated by advisors for their firm, and the quality of the advisors’ practices. Investment performance is not an explicit criterion because performance is often a function of each client’s appetite for risk. In evaluating advisors, they examine regulatory records, internal company documents, and 100-plus points of data provided by the advisors themselves. There is no fee to participate. Additional details regarding the criteria and process utilized in formulating these rankings can be found by at http://www.barrons-conferences.com/advisor-rankings.html

*Forbes’ ranking of America’s Top Next-Generation Wealth Advisors, developed by SHOOK Research, is based on an algorithm of qualitative and quantitative data, rating thousands of professionals with a minimum of four years relevant experience. Factors reviewed include revenue trends, assets under management, compliance records, industry experience and best practices. Also, interviews are held via telephone and in-person conversations. Portfolio performance is not a criteria due to varying client objectives and lack of audited data. There is no fee to participate.

*The Forbes ranking of America’s Top Women Wealth Advisors, developed by SHOOK Research, is based on an algorithm of qualitative and quantitative data, rating thousands of wealth advisors with a minimum of seven years of experience and weighing factors like revenue trends, assets under management, compliance records, industry experience and best practices learned through telephone and in-person interviews. Portfolio performance is not a criteria due to varying client objectives and lack of audited data. Neither Forbes or SHOOK receive a fee in exchange for rankings. Additional details regarding the criteria and process utilized in formulating these rankings can be found by at https://www.forbes.com/sites/rjshook/2019/02/20/forbes-best-in-state-wealth-advisors-methodology-2019/#3ac8af774ed1

*InvestmentNews’ Best Places to Work for Financial Advisors recognition is a survey competition to determine which participants are the best employers. The process is managed by Best Companies Group (BCG) and winners are published in an issue of Investment News. The process includes 2 surveys to gather detailed data about each participating company. BCG conducts the surveys, analyzes the data and determines the winners and rankings.

*Financial Advisor’s Young Advisors to Watch criteria is based on nominations from influential industry professionals of advisors age 40 and below – if more than one professional nominates a candidate, they are then considered on a number of qualitative factors, including thought leadership, innovative thinking, and more. Assets and accreditation are not factored into this recognition. There is no fee to participate.

*Crain’s Custom editors choose candidates based on their professional, civic and philanthropic achievements. For Notable Women in Finance, they only considered candidates working in asset management, banking, capital markets or credit cards who worked within the five boroughs of NYC. They often try to choose candidates who greatly contribute to the advancement of women in their workplace or industry as a whole.
The Family Business Awards program honors family businesses that make up the backbone of the American economy. Companies must be family owned and operated, headquartered in New York, and generate a minimum of $2.5 million in annual revenue. There is no fee to participate in the ranking. Honorees are evaluated and chosen by an independent panel of local business leaders and assessed based on their company governance, growth, internal processes and building a legacy.

*AdvisoryHQ’s ranking methodology is based on a wide range of filters including fiduciary duty, level of customized service, and history of innovation. There is no fee to participate. Details regarding Advisory HQ’s selection methodology can be found at http://www.advisoryhq.com/articles/advisoryhqs-methodology-for-selecting-top-advisors/

*InvestmentNews’ Top 20 Most Influential Women to Watch in 2016 eligibility criteria establishes that a recipient has demonstrated success and leadership in the financial advisory industry, has the ability to effect change in the industry, has exhibited a willingness to share her expertise with others through mentorship and public speaking, has a record of serving as a role model to other female professionals, and has given back to her community. There is no fee to participate in the ranking.

*The “30 Most Influential” program recognizes NAPFA members and staff who have made an impact on fee-only financial planning, the group and their peers since NAPFA’s founding in 1983.

*InvestmentNews’ and Invest in Others Charitable Foundation presents the Community Leadership Award to a financial advisor who has shown remarkable charitable leadership and personal commitment.

*IMPACT Award Nominations are made by industry professionals and judged by a panel of recognized experts. The IMPACT Awards recognize independent investment advisors who have fundamentally changed the financial services landscape by providing independent advice to affluent investors. There is no fee to participate in the ranking. Established by Schwab Institutional, this award recognizes these contributions by honoring advisors who have advanced the industry through their visionary leadership, operational excellence and technology innovation.

*The Financial Times 300 Top Registered Investment Advisers list is independently produced by Financial Times. The FT 300 is based on data gathered from RIA firms, regulatory disclosures, and FT’s research. The listing reflects each practice’s performance in six primary areas: assets under management, asset growth, compliance record, years in existence, credentials and online accessibility. This award does not evaluate the quality of services provided to clients and is not indicative of the practice’s future performance. There is no fee to participate.

*The Financial Times Top 100 Women Financial Advisors list is independently produced by Financial Times. Advisers have to manage at least $200 million in assets under management (AUM) and have 10 years of experience. Qualified advisers were then scored on six attributes: AUM, AUM growth rate, compliance record, experience, industry certifications and online accessibility. There is no fee to participate.

*The Financial Advisor ranking of leading Registered Investment Advisors in the US looks at year end assets under management of RIAs, publishing a ranked list by AUM. There is no fee to participate.

*Research Magazine inducts Advisor Hall of Fame honorees who pass their screening process, have served a minimum of 20 years in the industry, have acquired substantial assets under management, have demonstrated superior client service and have earned recognition from their peers and the broader community for the honor they reflect on their profession. There is no fee associated with securing this honor.

*The Financial Planning Influencer Award is presented to a practitioner who has made significant contributions to the financial planning profession. The Lifetime Achievement Award is given for advancing the industry throughout the course of a recipient’s career, thus changing financial planning for the better. There is no fee associated with consideration of this honor.

*Medical Economics’ 150 Best Financial Advisors for Doctors list highlights advisors with expertise in working with doctor clients. The publication reviews peer references, conducts a background check, & reviews data submitted by the advisor. A particular focus is given to fee-only financial advisors due to their objective advice.

*Dental Practice Report’s Best Financial Advisors for Dentists list reviews recommendations from dentists and conducts a review of the advisor’s professional conduct to ensure that there are no disciplinary action against the advisor. Candidates must have 10 years of professional experience and submit a questionnaire that highlights credentials, achievements, and information regarding work with dentists.

*The InvestmentNews Best Practices awards recognize top-performing firms that are run by people with a long-term vision for their organizations and an ongoing commitment to improving as well as enhancing their businesses. Recipients are all participants in InvestmentNews’ Research initiatives and chosen based on their rate of growth, profitability and productivity levels. There is no fee to participate in InvestmentNews’ Research initiatives.

*Nominations for an All-Star Research Team are sought from readers of Financial Advisor and Private Wealth Management magazines as well as from attendees of the Fiduciary Research Manager Summit. Nominations from individuals outside a nominee’s firm are weighted far more heavily than those who were nominated by themselves or their partners. There is no fee to participate in the ranking. Frequency of a nomination also played a role in selection. While the top nominees have different investment philosophies and disciplines, they all have a practice or strategy that sets them apart. There is no fee to participate in the nomination process.

*Wealth Manager identified the Top 50 Distinguished Women in Wealth Management by reviewing the net positive impact candidate have had on the wealth management profession, particularly through leadership and mentorship. There is no fee to participate in the recognition.

*AdvisorOne’s (previously known as Wealth Manager) Top 150 Wealth Manager ranking, previously known as Bloomberg’s Top 300 Wealth Managers ranking, is an independent listing of Registered Investment Advisors. Applicants submit a thorough application, which includes assets under management, firm growth, client retention, and multi-year growth. There is no fee to participate in the ranking.

*Worth’s Top 250 Wealth Advisors award requires nominees to have a minimum of 10 years of experience. Nominations, compensation structure, client retention, professional designations, and professional longevity are some of the criteria reviewed. There is no fee to participate in the ranking.

Rankings and recognition by unaffiliated publications should not be construed by a client or prospective client as a guarantee that Altfest will provide a certain level of results in client accounts nor should they be construed as current or past endorsements of Altfest by clients. Listed publications base their selection on publicly available information. Altfest is not responsible for any content prepared by outside publications regarding the products or services offered by Altfest.

Disclosure:

Altfest Personal Wealth Management is a Registered Investment Advisory firm registered with the United States Securities and Exchange Commission, Washington, D.C. In addition, the firm maintains a “Notice Filing” with the states of New York, New Jersey, Connecticut, Arizona, California, Florida, Illinois, Louisiana, Maryland, Massachusetts, New Hampshire, Pennsylvania, Texas, Vermont, and Virginia. Altfest Personal Wealth Management may not provide investment advisory services to any resident of states in which the firm does not maintain a notice filing. The presence of this website on the Internet shall in no direct or indirect fashion be construed or interpreted to suggest that the firm is offering to sell or soliciting to provide investment advisory services to residents of any state or states in which the firm is not maintaining a notice filing.

Investment advisory services provided by Altfest Personal Wealth Management (“APWM”). All written content on this site is for information purposes only. Opinions expressed herein are solely those of APWM, unless otherwise specifically cited. Material presented is believed to be from reliable sources and no representations are made by our firm as to another parties’ informational accuracy or completeness. All information or ideas provided should be discussed in detail with an advisor, accountant or legal counsel prior to implementation.

All investing involves risk, including the potential for loss of principal. There is no guarantee that any investment plan or strategy will be successful.