Privacy Policy

Facts

WHAT DOES TRANSFORM WEALTH DO WITH YOUR PERSONAL INFORMATION?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What

The types of personal information we collect and share depend on the product or service you have with us. This information can include:
◼ Social Security number
◼ Assets and account balances
◼ Investment experience and account transactions
◼ Wire transfer instructions
When you are no longer our customer, we continue to share your information as described in this notice.

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Transform Wealth chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information Does Transform Wealth share? Can you limit this sharing?
For our everyday business purposes—
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
Yes No
For our marketing purposes—
to offer our products and services to you
No We don’t share
For joint marketing with other financial companies No We don’t share
For our affiliates’ everyday business purposes—
information about your transactions and experiences
Yes No
For our affiliates’ everyday business purposes—
information about your creditworthiness
No We don’t share
For nonaffiliates to market to you No We don’t share

Questions?

Call Mark Riley, Chief Compliance Officer at 720-509-3558 or go to our website at www.transformwealth.com

Who we are
Who is providing this notice? Transform Wealth
What we do
How does Transform Wealth protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does Transform Wealth collect my personal information? We collect your personal information, for example, when you:

• Open an account or give us your income information
• Tell us about your portfolio or deposit money
• Enter into an investment advisory contract
• Instruct us to send money

We also collect your personal information from other companies.

Why can’t I limit all sharing? Federal law gives you the right to limit only:

• Sharing for affiliates’ everyday business purposes—information about your creditworthiness
• Affiliates from using your information to market to you
• Sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

Definitions
Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies.

• Our affiliates include Focus Operating, LLC.

Nonaffiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies.

• Transform Wealth does not share with nonaffiliates so they can market to you.

Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

• Transform Wealth does not jointly market.