EPIPHANY FINANCIAL COACHING, LLC

PRIVACY POLICY

Epiphany Financial Coaching, LLC (“EFC” or “Adviser”) is covered under the definition of a “financial institution” as set forth in the Federal Gramm-Leach-Bliley Act (the “Act”). EFC is therefore subject to Act and the privacy rules established by the office of the Kansas Securities Commissioner and other states where we may do business.

Privacy of nonpublic personal information is an issue that the staff of EFC takes seriously. In compliance with privacy rules, EFC has adopted policies and procedures reasonably designed to safeguard client and consumer records and information. 

In its role as Investment Adviser, EFC routinely collects nonpublic personal information from clients and prospective clients. This information generally will include but is not limited to:

  • Information provided in applications, forms and other data provided to us either verbally or in writing, and include but are not limited to your name, address, phone number, account information, social security number, assets, employment, income and debt, email address, etc.

  • Information about your transactions, accounts, trading activity and parties to transactions; health and beneficiary information (such as may pertain to financial planning issues)

  • Information received from other outside sources

  • Any other data that is deemed to be nonpublic personal information as defined by the Act and state privacy rules.

EFC values our clients’ trust and confidence. We will never sell our client’s nonpublic personal information. 

All information provided by clients or prospective clients to EFC, (including the Adviser’s personnel), and information and advice furnished by the Adviser to clients, shall be treated as confidential and shall not be disclosed to unaffiliated third parties, except as directed by clients with written authorization, by application to facilitate the investment advisory services offered by the Adviser via an unaffiliated financial services provider (such as Matson Money and the client’s custodial firm or broker/dealer), or as required by any rule, regulation or law to which the Adviser or its staff may be subject. 

You may request your financial information be shared with your attorney, CPA, tax preparer, or other service provider via written/email  request. Requests may entail a one-time request to provide data or may be a standing order. You are welcome to revoke such authorizations at any time by providing written notice (letter or email) to EFC or the other service provider engaged in sharing your information.

EFC maintains clients records in a controlled environment and records (electronic and otherwise) are only available to EFC’s authorized persons who have a need to access client information in order to deliver advisory services, provide administrative support, or to respond to client requests. The Adviser has made reasonable efforts and conducts periodic tests to ensure that its electronic workstations are secure and hack-proof.

EFC’s position on protecting non-public personal information extends beyond the life of the client agreement. Client information is retained in a protected manner for the time period required by regulators (five years from the data of last use) and thereafter is safely destroyed via electronic means or via in-house shredding. 

Consumers (who are not clients) who provide information during an initial consultation or for other purposes but do not go on to become clients of the Adviser also receive privacy protection. Original information will be promptly returned in person. Alternatively, if nonpublic personal information is contained in copies of documents, notes or some other media, this information will be securely filed for a period of up to one year (depending upon likelihood of engagement) before being shredded in-house. 

Clients are encouraged to discuss any questions regarding EFC’s privacy policies and procedures with Brendon Jenks, Chief Compliance Officer.