Privacy Policy
Avance Private Wealth Management, LLC ("Avance," "we," "us," or "our") is a registered investment adviser. This Privacy Policy describes how we collect, use, share, and protect information you provide when using our secure document portal at avancepwm.com. It supplements our annual Regulation S-P privacy notice delivered to clients at onboarding and each year thereafter.
Information We Collect
When you use the document portal, we collect:
- Identity information — your name and email address, which you provide to authenticate your session
- Documents you upload — financial statements, tax returns, account documents, and any other files you submit through the portal
- Authentication data — one-time verification codes and, if you create one, a 4-digit access PIN (stored as a one-way cryptographic hash; we cannot recover your PIN)
- Usage data — IP address, browser type, and timestamps of logins, uploads, and file downloads, recorded in a tamper-evident audit log
- Optional messages — any note you attach to a document submission
How We Use Your Information
We use the information we collect solely to provide investment advisory services to you:
- To receive and organize documents you submit for your advisory relationship
- To automatically categorize uploaded documents using an AI classification tool (described below) so your advisor can locate them efficiently
- To send you email confirmations of successful uploads and advisor messages
- To maintain a security audit log for compliance and fraud prevention purposes
- To fulfill our recordkeeping obligations under the Investment Advisers Act of 1940
We do not sell, rent, or trade your personal information or documents to any third party for marketing or commercial purposes.
AI-Assisted Document Classification
When you upload a document, it is processed by an AI classification service to automatically identify the document type (e.g., "Tax Return," "Account Statement") and generate a brief descriptive label. This classification assists your advisor in organizing your file — it does not replace advisor review and is not used to make any investment decisions.
Document content is transmitted securely to the classification service and is not retained beyond the processing of the individual request. The service provider is contractually prohibited from using submitted content to train AI models.
Third-Party Service Providers
We work with a limited number of service providers to operate this platform. Each is engaged under contractual obligations to handle your data only as directed by us and solely for the purpose of providing services to Avance:
| Service type | Purpose | What they receive |
|---|---|---|
| Cloud document storage | Secure storage of uploaded files | Your uploaded documents, stored in an encrypted, access-controlled environment. The provider is SOC 2 Type II certified and encrypts data at rest and in transit. |
| Application hosting & database | Portal infrastructure and account records | Your name, email, hashed PIN, upload metadata, and audit log. No document content is stored in the application database — only file metadata and access records. |
| Email delivery | Transactional notifications | Your name, email address, and the content of notification emails (upload confirmations, verification codes, advisor messages). Emails are transmitted securely via TLS. |
| AI document classification | Automated document categorization | Document content is processed for classification only and is not retained or used to train AI models under the terms of our service agreement. |
Data Security
We implement multiple technical and organizational safeguards to protect your information:
- All data in transit is encrypted using TLS 1.2 or higher
- Documents are stored in Box with AES-256 encryption at rest
- Portal access requires email-verified one-time codes or a PIN you set yourself
- Admin access is protected by password authentication, CSRF tokens, and a session idle timeout
- A cryptographically chained audit log records all access and upload events; the chain is tamper-evident
- Upload capabilities are rate-limited to prevent abuse
- File types are validated and all uploads are converted to PDF before storage
Data Retention
We retain your information in accordance with regulatory requirements for registered investment advisers:
- Client records and correspondence — minimum 5 years per SEC Rule 204-2
- Uploaded documents — retained in Box for the duration of your advisory relationship and 5 years thereafter, unless you request earlier deletion consistent with applicable law
- Audit log — retained for a minimum of 5 years
- Email verification codes — automatically purged after 10 minutes
- Session data — expires after 30 minutes of inactivity
Your Rights
You may contact us at any time to:
- Request a copy of the personal information we hold about you
- Request correction of inaccurate information
- Request deletion of your information, subject to our regulatory retention obligations
- Ask questions about how your data is used or stored
To exercise these rights, contact us at info@avanceprivate.com.
Regulation S-P Notice
As a registered investment adviser, Avance is subject to the SEC's Regulation S-P (Privacy of Consumer Financial Information). We do not share nonpublic personal information about you with nonaffiliated third parties except as permitted by law (for example, with service providers as described above, or as required by legal process). You have the right to receive our annual privacy notice; please contact us if you have not received it.
Changes to This Policy
We may update this policy from time to time. Material changes will be communicated to clients directly. The current version is always available at avancepwm.com/privacy.
Contact
Avance Private Wealth Management, LLC
info@avanceprivate.com