Effective Date: November 10, 2025

Braeburn Wealth Management, Inc. (“Braeburn,” “we,” “our,” or “the Adviser”) is committed to safeguarding the confidentiality and integrity of personal information entrusted to us. As a Registered Investment Adviser, we comply with the Gramm-Leach-Bliley Act (GLBA), the Securities and Exchange Commission’s Regulation S-P, the FTC Safeguards Rule, and applicable state data-privacy laws.

This Privacy Policy describes how we collect, use, disclose, and protect nonpublic personal information.

1. Information We Collect

We collect information necessary to provide investment advisory, financial planning, and related services, including:

Information You Provide

Name, address, email address, and phone numbers
Social Security number or taxpayer ID number
Date of birth
Employment information
Financial information: income, assets, liabilities, investment experience, and risk tolerance
Health-related or beneficiary information (when relevant to planning or insurance-related recommendations)

Information from Transactions and Accounts

Account balances, holdings, performance history
Transaction records, deposits, withdrawals
Account communications and service requests

Information from Third Parties

Custodians and financial institutions
Attorneys, accountants, insurance agents, or other authorized representatives
Public records and identity-verification sources

Information Collected Automatically When You Visit Our Website

IP address, browser type, operating system
Device identifiers
Pages visited, time on page, and click-stream data
Cookies, pixels, and tracking technologies
Analytics tools (e.g., Google Analytics)
Log data related to site performance, security, and visitor interactions

You may adjust browser settings to decline cookies, but doing so may impact site functionality.

2. How We Use Your Information

We use personal information for legitimate business and regulatory purposes, including:

Delivering advisory, planning, portfolio management, and reporting services
Opening, maintaining, administering, or servicing accounts
Communicating with you regarding your accounts, services, or updates
Processing transactions and providing operational support
Verifying identity and preventing fraud
Meeting compliance and regulatory obligations
Maintaining business records
Responding to inquiries, requests, or instructions
Analytics, website performance, and security monitoring

We do not sell personal information.

3. How We Share Information

We only share information under the following permitted circumstances:

With Your Authorization

Sharing with attorneys, accountants, insurance agents, or other professionals you instruct us to work with.

With Service Providers and Vendors

We may share information with trusted third-party providers who support our business operations, including:

Custodians and broker-dealers
Technology providers, custodial platforms, CRM systems, secure data-storage providers
Portfolio reporting systems
Compliance consultants
Independent auditors and legal counsel

These providers are required to maintain confidentiality and use information only for intended purposes.

As Required or Permitted by Law

We may disclose information in response to:

SEC or regulatory examinations
Court orders or subpoenas
Governmental investigations
Required compliance filings
Fraud-prevention or cybersecurity investigations

No Sharing for Marketing

We do not disclose nonpublic information to non-affiliated third parties for marketing purposes.

4. Protection of Your Information

We maintain administrative, technical, electronic, and physical safeguards to protect your information from unauthorized access, including:

Restricted access controls limited to employees with a legitimate business need
Password-protected and encrypted systems
Secure electronic storage and transmission protocols
Firewalls, malware detection, and intrusion-prevention systems
Employee privacy and cybersecurity training
Vendor due-diligence oversight

5. Data Breach Notification Procedure

If a data incident or unauthorized access occurs, we will:

Investigate promptly
Secure affected systems
Notify impacted clients as required under federal or state law
Provide guidance on remedial steps (credit monitoring, fraud alerts, etc.)

6. Retention and Destruction of Information

We retain personal information for the period required by regulatory rules, including SEC Rule 204-2, and additional time as necessary for business or legal purposes.

Once retention periods expire, information is securely destroyed using:

Secure shredding
Data wiping
Permanent deletion protocols

7. Former Clients

We maintain the confidentiality of former clients’ information under the same standards applied to current clients. Information is not shared except as required by law.

8. Your Rights Under State Privacy Laws

If you are a resident of California, Colorado, Connecticut, Virginia, or other states with consumer privacy laws, you may have specific rights, including:

Right to know what personal information is collected
Right to request access to or deletion of personal information
Right to request correction of inaccuracies
Right to limit use of sensitive personal information
Right to opt-out of data “selling” or “sharing” (we do not sell data)
Right to receive information in a portable format

To exercise these rights, contact us using the information below. We will verify your identity before responding.

9. Children’s Privacy

Our services are not directed to individuals under age 13. We do not knowingly collect information from children.

10. Annual Privacy Notice

We provide privacy notices at account opening and annually thereafter, consistent with Regulation S-P.

11. Updates to This Policy

We may update this Privacy Policy periodically. The “Effective Date” at the top will reflect the latest revision. Continued use of our services constitutes acceptance of the updated policy.

12. Contact Information

If you have questions about this Privacy Policy or our data-handling practices, contact:

Michael Poland, CFA®
President & Chief Compliance Officer
Braeburn Wealth Management, Inc.
111 West Western Ave.
Muskegon, MI 49442
(231) 720-0743
[Insert Compliance Email Address]