PRIVACY POLICY

Effective Date: March 31, 2026

Canterbury Consulting Incorporated (“CCI”, “we”, or “us”) is committed to protecting your privacy and security.  We want you to understand how we collect and use information from our websites, client portal,  and other platforms (collectively the “Sites”) that link to this Privacy Policy or use our financial services (the “Services”). We respect your right to privacy when you use our Sites, our Services, communicate with us electronically, and otherwise provide us with your Personal Information. We have developed this Privacy Policy to inform you of how we handle the Personal Information you provide us.

By using the Sites and/or our Services, you agree to the terms of this Privacy Policy linked at the bottom of any of the Sites. If you do not agree to the terms of this Privacy Policy, please do not use our Sites or Services and please do not submit any Personal Information to us through a mobile device or otherwise.

Our careers webpage (https://www.canterburyconsulting.com/careers) uses a third-party service provider to enable applications on the website and to process job applications on our behalf. The Personal Information processed through the careers website is subject to this Privacy Policy. When you access our careers webpage or submit a job application through the Site, you may be directed to or interact with a platform operated by the third-party. We encourage you to review the third-party terms and privacy policy before submitting any information via our careers webpage, as your use of the third-party platform may be subject to the third-party’s own terms of use and privacy policy. By submitting Personal Information through our careers webpage, you acknowledge and agree that your information will be processed by the third-party in accordance with its applicable terms and policies, and that we are not liable for any loss or damage arising from the third-party’s handling of such Personal Information.

Notice at Collection for California Consumers: If you are located in California, please review our Privacy Notice for California Residents appended as a supplement to this Policy.

I. Information We Collect

“Personal Information” refers to any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.

Personal Information you submit through the Sites may include your name, email address, company affiliation, job title, postal address, phone number, username, password, employment-related details, information related to services we provide to you (e.g., financial information via our client portal) and any other Personal Information that you choose to disclose. In some cases, you may choose not to provide Personal Information, but this may prevent you from using certain features of our Sites.

We may collect Personal Information about you that you provide to us through our Sites, such as when you:

• fill out our “Contact Us” form;
• register for and attend events such as webinars, conferences, and seminars;
• access our client portal;
• pay invoices;
• sign up for email newsletters;
• contact us with inquiries, including via email;
• engage with our Sites;
• seek customer support; or
• otherwise voluntarily provide information.

We may also collect data regarding your use of our Sites, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data.

Additionally, we may collect Personal Information automatically via tracking technologies on our Sites, including cookies, which are used to collect information about your interactions with our Sites. Descriptions of cookies are provided in the following section on online tracking technologies.

We do not collect, use, or sell personal information for the purpose of training large language models.

When you engage in our Services, we may also collect and use various types of information, including Non-Public Information as defined under the Gramm-Leach-Bliley Act, to administer our business and offer you the best possible customer service.  This includes:

• Information we receive from you on applications, or on other forms, through telephone or in-person interviews, such as your name, address, phone number, Social Security number, your assets, income, and other household information;
• Information about your transactions and account experience with us or others, such as your account balance or transaction history;
• Other general information we obtain about you that is assembled for the purpose of opening an account or offering certain products or services that you may request.

II. Online Tracking Technologies

We use cookies and similar technologies such as tracking pixels and web beacons (collectively referred to as “cookies”) to collect user activity information, including your browsing activities and preferences. We may use the following types of cookies:

• Analytics Cookies. We use analytics tools to collect information about how visitors use our Sites. This includes information such as pages visited, time spent on pages, and general geographic location. This data helps us improve the performance and user experience of our Sites.
• Necessary Cookies: These cookies are necessary for the Sites to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms.

Our Sites’ cookie management tool is configured to honor opt-out preference signals sent by Global Privacy Control (“GPC”) within your browser. Please note that due to technical limitations, the GPC signal may only be recognized within your current browser. For more information on GPC please visit https://globalprivacycontrol.org.

Though we adhere to standards set out in this privacy policy related to online tracking technologies, our Sites do not currently respond to ‘Do Not Track’ signals.

III. Information Use

We process Personal Information for a variety of purposes, including to:

• Maintain reasonable security measures.
• Conduct our employee recruiting processes.
• Communicate with customers and prospective customers.
• Solicit feedback from customers and prospective customers.
• Operate, manage, and run our business and maintain records.
• Provide, develop, improve, and maintain our products and services in accordance with professional standards.
• Collect and analyze information about characteristics and behavior of visitors to our Sites.
• Detect and prevent fraud and perform identity verification.
• Perform accounting, audit, and other internal functions, such as internal investigations.
• Comply with law, regulation, legal process, and internal policies.
• Exercise and defend legal claims.
• For any other purpose you may agree to at or before the time your Personal Information is collected.

IV. Information Disclosure

We may disclose Personal Information in the following ways:

• To service providers, contractors, processors, and other third parties who provide services on our behalf.
• To affiliates and subsidiaries within our corporate family to perform services in accordance with professional standards.
• In connection with the sale, assignment, or other transfer of the business of the Sites to which the information relates, in which case we will require any such buyer to agree to treat it in accordance with this Privacy Policy and use it only for the same purposes.
• Responding to law enforcement requests or where required by applicable laws, court orders, or government regulations.
• To third parties as deemed necessary to comply with legal requirements or to establish or exercise our legal rights to defend against legal claims.
• When we believe it is necessary to share information to assist in an investigation regarding, or to prevent, illegal activities, suspected fraud, or potential threats to the safety of any person.

CCI does not sell Personal Information for monetary consideration, though certain of our digital analytics may constitute a “sale” or “sharing” of Personal Information as those terms are defined under applicable privacy laws (see further discussion in Your Privacy Rights and Privacy Notice for California Residents sections below).

V. Your Communication Choices

You may opt out of receiving email marketing communications from us by clicking the unsubscribe link included in our emails or by contacting us as described below. Please note that we may still send you transactional and administrative emails even if you opt out of marketing communications.

VI. Important GLBA Notice

Certain Personal Information we collect and process in connection with providing financial advisory services is subject to the Gramm‑Leach‑Bliley Act (“GLBA”) and related regulations. Information subject to GLBA is exempt from many state privacy rights described in this section, including rights of access, deletion, and portability.

VII. Your Privacy Rights

Depending on your state of residency, you may have certain privacy rights, subject to certain exceptions, as follows:

• Right to Access. You may have the right to request that we disclose what Personal Information we collect, use, disclose, and sell about you.
• Right to Correction. You may have the right to request correction of Personal Information that we maintain about you if you find that the Personal Information is inaccurate.
• Right to Deletion. You may have the right to request that we delete Personal Information that we have collected from you.
• Data Portability. You may have the right to request a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format.
• Right to Withdraw Consent. You may have the right to withdraw your consent to the processing of your Personal Information.
• Right to Limit Use and Disclosure of Sensitive Personal Information. You may have the right to limit the processing of your sensitive Personal Information.
• Right to Opt-Out. You may have the right to opt-out of certain uses of your Personal Information such as for (i) targeted advertising, (ii) “sale” or “sharing” for cross-context behavioral advertising, or (iii) profiling or automated decision-making activities that result in a legal or similarly significant effect on you. However, we do not engage in (i), (ii), or (iii).
• Right to Information on Profiling. Should your Personal Information be processed for the purposes of profiling in furtherance of any automated decision that produced any legal or similarly significant effect concerning you, and if feasible, you may have the right to (i) question the result of such profiling, (ii) be informed of the reason that such profiling resulted in such decision, and (iii) review your personal information that was processed for the purposes of such profiling. However, we do not engage in the use of Personal Information for profiling or automated decision-making activities.
• Right to Information on Third Parties. Should your Personal Information be sold to third parties, you may have the right to obtain a list of the third parties to which your personal information was sold.
• Right to Appeal. In some circumstances, we may deny your request to exercise one of your privacy rights described in this Privacy Policy (e.g., if we cannot verify your identity). In such a case, we will communicate this to you in writing and explain the reasons for the denial. You may appeal our decision by responding to our denial email or submitting a request to [EMAIL]. We will notify you of our decision regarding your appeal in writing via an email from [EMAIL] within 45 days of receipt. If we deny your appeal, you may have the right to contact your state Attorney General to file a complaint.

Requests to exercise these rights may be made using the contact information listed at the end of this Privacy Policy, or as otherwise described in this section. Only you or, as permitted by law, a person that you authorize to act on your behalf, may make a request related to your Personal Information. For certain requests, we must verify your request before we can fulfill it. Verifying your request will require you to provide sufficient information for us to reasonably confirm that you are the person about whom we collected Personal Information or that the requestor is authorized to act on your behalf. We will not discriminate against you for exercising your privacy rights.

VIII. Information About Children

The Sites are not intended for children under the age of 18.  We do not knowingly collect Personal Information via the Sites from visitors under the age of 18. If you believe that we have unintentionally collected Personal Information about your child, you can contact us as described below.

IX. Security

CCI takes reasonable steps to protect Personal Information as you transmit it to our Sites and to protect such Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.  You should know and consider that no Internet or mobile device transmission, including text messages, is ever completely secure or error-free. As a result, while we strive to protect your Personal Information, we cannot guarantee that it will be 100% secure. Your transmission of your information to our Sites thus is done entirely at your own risk.

X. Retention of Personal Information

We retain the Personal Information we collect for the time period required to fulfill the legitimate business purposes for which it was collected and to engage in the use and disclosure practices outlined in this Privacy Policy, unless a different retention period is required by applicable law, or otherwise to fulfill a legal obligation or protect our legal rights.

XI. Links to Other Websites

The Sites may contain links or references to other websites to which this Privacy Policy does not apply. We encourage you to read the Privacy Policy of every website you visit.

XII. Updates

We reserve the right to update this Privacy Policy from time to time, so please review it regularly. If we make material changes to our information handling practices or this Privacy Policy, we will contact you through your provided email address or by posting those changes on this Privacy Policy. Your continued use of our Services will be deemed your agreement that your information may be used in accordance with the new policy.  If you do not agree with the changes, then you should stop using the Services and notify us that you do not want your information used in accordance with the changes. 

XIII. How to Contact Us

If you have any questions, comments, or concerns about this Privacy Policy or our information protection practices, please contact us as follows:

info@canterburyconsulting.com

or

(949) 721-9580

or

610 Newport Center Drive, Suite 500

Newport Beach, CA 92660

 

SUPPLEMENTAL NOTICE
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective Date: March 31, 2026

This Privacy Notice for California Residents supplements the information contained in the CCI Privacy Policy above (“Privacy Policy”), and applies only to California residents (“you,” “your” or “consumer”). This section provides additional disclosures for residents of California, as required by the California Consumer Privacy Act, as amended (the “CCPA”). Please remember that the information we collect varies based on our relationship with you and note that certain Personal Information or activities may not be reflected in this section because they are exempt from the CCPA. 

I. CCPA Categories of Personal Information We Collect, How and Why We Collect Them

We collect the following categories of Personal Information about California consumers. This information may be, or may have been, collected directly from you, automatically when you use our Services, from third parties, or from publicly available sources.

• Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, or account name.
• Personal Information described in Cal. Civ. Code § 1798.80(e), including name, electronic signature, address, telephone number, education, employment history, bank account information, or other financial information.
• Characteristics of protected classifications under California or federal law, including age and date of birth. Additional protected classification characteristics may also be collected from job applicants such as veteran status, race or ethnicity.
• Commercial information, including names, addresses, phone numbers, and business ownership.
• Internet or other electronic network activity information, including Internet or other similar activity, browsing history, app use, device ID, etc.
• Geolocation data, including location data inferred from your device IP address.
• Audio, electronic, visual, thermal, olfactory, or similar information, including audio recordings of customer calls and webinars.
• Professional or employment-related information, including business contact information as well as information collected from job applicants during the hiring process including resumes, cover letters, education history, employment history, and background check information.
• Non-public education information, including transcripts or other information which may be collected during the hiring process.

We use the Personal Information we collect for the purposes described in the Information Use section of our Privacy Policy.  We do not collect any Sensitive Personal Information.

II. CCPA Categories of Personal Information Disclosed

We disclose all of the above categories of Personal Information to service providers or to other third parties as described in the Information Disclosure section above.

III. CCPA Categories of Personal Information Sold or Shared

Under the CCPA, a “sale” of Personal Information includes disclosures of Personal Information to third parties who may use the information for their own purposes, such as analytics and advertising partners. Similarly, “sharing” Personal Information refers to disclosing Personal Information to third parties for cross-context behavioral advertising. Per these definitions, we may sell and/or share the following categories of Personal Information to third party analytics and advertising partners:

• Identifiers
• Personal Information described in Cal. Civ. Code § 1798.80(e)
• Commercial information
• Internet or other electronic network activity information
• Geolocation data
• Inferences
• Sensitive Personal Information (e.g., precise geolocation)

California residents should refer to the Your Privacy Rights section of our Privacy Policy for information regarding their privacy rights under the CCPA and how to exercise them.

You have the right to direct us to not share, disclose, or sell your Personal Information. To exercise this right, you or your authorized representative may submit a request by clicking on the [Do Not Sell or Share My Personal Information link on the homepage of our Sites]. 

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Sites that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes.

IV. Contact Us

If you have any questions, comments, or concerns about this Privacy Notice for California or our information protection practices, please contact us as follows:

If you have any questions, comments, or concerns about this Privacy Policy or our information protection practices, please contact us as follows:

610 Newport Center Drive, Suite 500  | info@canterburyconsulting.com  |  (949) 721-9580 

Newport Beach, CA 92660