Website Privacy Policy

1. Scope of This Policy

This policy applies to personal information collected through the Pathfinders Wealth website, scheduling tools, website forms, email links, and other online features that link to this policy.

This policy does not replace any financial privacy notice, client agreement, insurance-company privacy notice, custodian privacy notice, or other disclosure that applies after you establish an advisory, insurance, or other financial-services relationship.

Investment advisory services are offered through Foundations Investment Advisors, LLC, an SEC-registered investment adviser. Foundations may provide a separate privacy notice governing nonpublic personal information collected in connection with an advisory relationship.

2. Information We Collect

Information You Provide to Us

We collect information you voluntarily provide when you:

• Schedule a conversation
• Send us an email or question
• Call us
• Request information
• Ask for a second opinion
• Subscribe to communications
• Respond to a survey or questionnaire
• Otherwise communicate with Pathfinders

This information may include:

• Your name
• Email address
• Telephone number
• Preferred meeting date or time
• Communication preferences
• General information about your financial-planning question
• Information about your retirement timing, goals, or concerns that you choose to provide
• Any other information included in your message

Please Do Not Submit Sensitive Financial Information

Do not submit any of the following through the website, scheduling form, or ordinary email:

• Social Security numbers
• Tax-identification numbers
• Account numbers
• Passwords or login credentials
• Copies of tax returns
• Bank or investment statements
• Credit-card information
• Driver’s-license or passport numbers
• Medical records
• Other sensitive personal or financial documents

When sensitive information is needed as part of an established relationship, we will direct you to an appropriate secure method for providing it.

Information Collected Automatically

When you visit the website, certain information may be collected automatically, including:

• Internet Protocol address
• Browser type
• Device type
• Operating system
• Approximate geographic location derived from your IP address
• Pages viewed
• Links selected
• Referring website
• Date and time of your visit
• Time spent on the website
• General interaction and navigation information
• Cookie and similar-technology identifiers

This information helps us operate, secure, maintain, and improve the website.

Information Received From Third Parties

We may receive information from third parties when you:

• Schedule through our calendar provider
• Interact with Pathfinders through a social-media platform
• Respond to an advertisement or educational program
• Are referred to us by another person or organization
• Use a third-party form, event-registration page, podcast platform, or similar service

The information we receive depends on your interaction with that third party and its privacy practices.

3. How We Use Personal Information

We may use personal information to:

• Respond to your questions
• Schedule, confirm, or manage appointments
• Understand what prompted your inquiry
• Determine the appropriate person to respond
• Provide information you requested
• Communicate with you about a potential relationship
• Send appointment reminders or follow-up communications
• Maintain records of inquiries and communications
• Operate, maintain, and improve the website
• Understand how visitors use the website
• Diagnose technical problems
• Protect the website, our systems, and our users
• Prevent fraud, abuse, or unauthorized activity
• Comply with regulatory, legal, compliance, or recordkeeping obligations
• Establish, exercise, or defend legal rights
• Carry out another purpose disclosed to you when the information is collected

If you become a client, additional uses of your information will be governed by the applicable agreements, disclosures, and privacy notices.

4. Appointment Scheduling and CRM Services

Our scheduling calendar is provided through a third-party scheduling and customer-relationship-management platform, currently LeadConnector/HighLevel.

When you schedule a conversation, information such as your name, email address, telephone number, selected appointment time, and information entered into the scheduling form may be transmitted to and stored by that provider.

The provider may also collect technical information through cookies, embedded content, or similar technologies.

Do not include account numbers, Social Security numbers, tax documents, or other sensitive financial information in the scheduling form.

Third-party providers process information according to their own terms, privacy policies, and contractual obligations to Pathfinders.

5. Cookies and Similar Technologies

The website and its service providers may use cookies, pixels, local storage, embedded scripts, and similar technologies.

These technologies may be used to:

• Enable website functionality
• Remember user preferences
• Maintain security
• Understand website traffic
• Measure page performance
• Diagnose technical issues
• Understand which content visitors find useful
• Support embedded scheduling or media features

You can control or delete cookies through your browser settings. Blocking some cookies may affect the functionality of the website or embedded services.

Do Not Track and Browser Privacy Signals

Some browsers offer a “Do Not Track” setting. Because there is not a single industry standard for responding to Do Not Track signals, the website does not currently respond to them in a uniform manner.

We do not currently sell personal information for money or use personal information collected through this website for cross-context behavioral advertising. Where applicable law requires us to recognize a legally valid browser-based opt-out signal, we will process that signal as required.

6. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients.

Pathfinders Personnel and Advisors

Information may be shared with the Pathfinders advisor or team member responsible for responding to your inquiry, scheduling a meeting, or supporting the relationship.

Foundations Investment Advisors

Information may be disclosed to Foundations Investment Advisors and its personnel when relevant to:

• A request for investment-advisory information
• Evaluating a potential advisory relationship
• Supporting investment-management or client-service functions
• Supervisory, regulatory, or compliance obligations
• Required recordkeeping
• Information-security or incident-response responsibilities

Service Providers

We may use service providers to support:

• Website hosting, including WP Engine
• Scheduling and customer-relationship management, including LeadConnector/HighLevel
• Email delivery
• Website maintenance
• Analytics
• Information technology
• Cybersecurity
• Data storage and backups
• Compliance and recordkeeping
• Professional services

These providers receive information only as reasonably necessary to perform services for Pathfinders or as otherwise permitted by law.

Legal and Regulatory Disclosures

We may disclose information when we reasonably believe disclosure is necessary to:

• Comply with law, regulation, subpoena, court order, or legal process
• Respond to a regulatory or governmental request
• Protect the rights, safety, or property of Pathfinders, our clients, or others
• Detect or prevent fraud, cybersecurity threats, or unlawful activity
• Enforce applicable agreements
• Meet legal, regulatory, supervisory, or recordkeeping obligations

Business Transactions

Information may be disclosed as part of a merger, acquisition, sale, financing, reorganization, transfer of assets, or similar business transaction, subject to applicable law and appropriate confidentiality protections.

With Your Direction or Consent

We may disclose information when you direct us to do so or provide consent.

7. Sale and Sharing of Personal Information

Pathfinders does not sell personal information for money.

Pathfinders does not currently share personal information collected through the website for cross-context behavioral advertising.

We may disclose personal information to service providers that process information on our behalf. Those service-provider disclosures are used to operate and support the website and are not intended to permit the provider to use the information for its own unrelated purposes.

If our practices change, we will update this policy and provide any choices required by applicable law.

8. Financial-Services and Client Information

Information collected after you establish an advisory, insurance, or other financial-services relationship may be subject to separate privacy notices and legal requirements.

Depending on the services involved, your information may also be governed by the privacy policies of:

• Foundations Investment Advisors
• Fidelity, Charles Schwab, or another independent custodian
• Insurance companies
• Financial-planning software providers
• Tax or legal professionals you authorize us to coordinate with
• Other product or service providers involved in your plan

The Pathfinders Website Privacy Policy does not replace those separate notices.

For Foundations’ regulatory documents and applicable financial privacy materials, use the footer link labeled:

Click here for Privacy Policy, Form CRS & ADV Part 2A

9. Email, Telephone, and Text Communications

When you provide an email address or telephone number, we may use it to:

• Respond to your inquiry
• Confirm or manage an appointment
• Provide information you requested
• Follow up regarding a conversation
• Communicate about a potential or existing relationship
• Send educational or marketing communications when permitted

You can unsubscribe from promotional email by using the unsubscribe link in the message or by contacting us.

You can request that promotional text messages stop by replying STOP or following the opt-out instructions provided in the message.

Opting out of promotional communications will not prevent us from sending communications necessary to respond to your request, manage an appointment, service an existing relationship, or comply with legal obligations.

10. Data Retention

We retain personal information for as long as reasonably necessary to:

• Respond to an inquiry
• Manage an appointment or relationship
• Provide requested services
• Maintain business and communication records
• Comply with legal, regulatory, compliance, or recordkeeping obligations
• Resolve disputes
• Enforce agreements
• Protect our systems and users

The applicable retention period depends on the type of information, why it was collected, whether a relationship was established, and any legal or regulatory requirements.

When information is no longer reasonably necessary, we may delete, de-identify, or securely dispose of it.

11. Information Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, alteration, loss, or disclosure.

These safeguards may include:

• Access controls
• Password and authentication requirements
• Secure hosting
• Encryption where appropriate
• Service-provider oversight
• Employee and advisor access limitations
• Security monitoring
• Backup and recovery practices
• Incident-response procedures

No website, communication system, or method of electronic storage is completely secure. We cannot guarantee that information transmitted through the internet or ordinary email will never be accessed, used, or disclosed without authorization.

If a security incident occurs, we will investigate and provide notices as required by applicable law.

12. Your Privacy Choices and Rights

Depending on where you live and subject to applicable exceptions, you may have the right to request that we:

• Confirm whether we process your personal information
• Provide access to personal information we maintain about you
• Correct inaccurate personal information
• Delete certain personal information
• Provide a copy of certain personal information
• Explain the categories of information collected
• Explain the purposes for which information is used
• Explain the categories of third parties to which information is disclosed
• Opt you out of certain sales, sharing, or targeted-advertising activities
• Limit certain uses of sensitive personal information
• Stop promotional communications

Pathfinders does not discriminate against individuals for exercising applicable privacy rights.

Submitting a Privacy Request

To submit a request, contact us using:

Email: [email protected]
Telephone: (248) 487-9148

Use the subject line:

Privacy Request

Please include enough information for us to understand your request and verify your identity. We may need to request additional information before responding.

An authorized agent may submit a request where permitted by law. We may require proof of authorization and may separately verify the request with the individual.

If applicable law gives you the right to appeal a decision concerning your privacy request, you may appeal by replying to our response and clearly stating that you are requesting an appeal.

13. California and Other State Privacy Disclosures

During the preceding twelve months, Pathfinders may have collected the following categories of personal information through the website:

• Identifiers, such as name, email address, telephone number, IP address, and online identifiers
• Internet or electronic-network activity, such as browsing and interaction information
• Professional or employment information voluntarily included in an inquiry
• General financial-planning information voluntarily provided by a visitor
• Inferences reasonably drawn from the nature of a visitor’s inquiry or expressed interests

This information is collected from:

• You
• Your browser or device
• Scheduling and CRM providers
• Referrals
• Social-media or content platforms
• Other service providers

We use and disclose these categories for the purposes described in this policy.

We do not knowingly sell these categories of personal information for money or share them for cross-context behavioral advertising.

Certain information handled in connection with a financial-services relationship may be subject to federal financial-privacy laws and separate financial privacy notices.

14. Children’s Privacy

The website is intended for adults and is not directed to children under 13.

We do not knowingly collect personal information online from children under 13. If we learn that a child under 13 has provided personal information through the website, we will take reasonable steps to delete it.

A parent or guardian who believes a child has submitted personal information can contact us at [email protected].

15. Third-Party Websites and Services

The website may contain links to or embedded features from third parties, including:

• Scheduling platforms
• Social-media platforms
• Podcast or video platforms
• Custodian websites
• Insurance-company websites
• AdviserInfo and regulatory websites
• Other educational or financial resources

Pathfinders does not control the privacy or security practices of third-party websites and services. Your interaction with those services is governed by their own privacy policies and terms.

We encourage you to review those policies before providing personal information.

16. Visitors From Outside the United States

The website is intended primarily for individuals located in the United States.

If you access the website from another country, your information may be processed and stored in the United States, where privacy laws may differ from those in your country.

17. Changes to This Policy

We may update this Website Privacy Policy from time to time to reflect:

• Changes to our website
• New technologies or service providers
• Changes to our information practices
• Legal or regulatory requirements
• Operational or security developments

The updated policy will be posted on this page with a revised “Last Updated” date.

If a change materially affects how we use previously collected personal information, we will provide additional notice when required by law.

18. Contact Us

Questions, concerns, or privacy requests can be directed to:

Pathfinders Wealth
Email: [email protected]
Telephone: (248) 487-9148

For information about Foundations Investment Advisors, Form CRS, Form ADV Part 2A, and applicable financial privacy materials, use the required regulatory-documents link in the website footer.