Privacy Policy
Polaris Financial LLC
Effective Date: March 15, 2026
Introduction
This Privacy Policy is provided by Polaris Financial, LLC a registered investment adviser with the U.S. Securities and Exchange Commission (SEC File No. 801-107177; CRD No. 281952), with its principal place of business at 6 Liberty Square #2663, Boston, Massachusetts 02109.
This notice is provided pursuant to Regulation S-P (17 C.F.R. Part 248), the Gramm-Leach-Bliley Act (“GLBA”) (15 U.S.C. §6801 et seq.), and applicable state privacy laws, including M.G.L. c. 93H and 201 CMR 17.00.
We created this Privacy Policy to describe how we collect, use, share, and safeguard personal information in connection with our website and investment advisory services.
This Privacy Policy applies to:
We will never rent or sell your information to anyone. If you have any questions regarding our privacy policy, please send us a note at [email protected]. We reserve the right to amend this privacy policy at our discretion and at any time.
This notice is provided pursuant to Regulation S-P (17 C.F.R. Part 248), the Gramm-Leach-Bliley Act (“GLBA”) (15 U.S.C. §6801 et seq.), and applicable state privacy laws, including M.G.L. c. 93H and 201 CMR 17.00.
We created this Privacy Policy to describe how we collect, use, share, and safeguard personal information in connection with our website and investment advisory services.
This Privacy Policy applies to:
- Visitors to our website
- Users of our digital tools
- Prospective clients
- Individuals who receive investment advisory services
- Businesses who receive investment advisory services
We will never rent or sell your information to anyone. If you have any questions regarding our privacy policy, please send us a note at [email protected]. We reserve the right to amend this privacy policy at our discretion and at any time.
Information We Collect
Website Visitor Information
Cookies are small pieces of data that are stored on your computer, mobile device, or other device used to access the internet. Pixels and similar technologies are small blocks of code on a website that allow information to be collected about how visitors use the site.
We use cookies and similar technologies to operate our website, analyze website usage, and improve site performance and user experience. These technologies collect information such as browser type, device type, operating system, IP address, general geographic location, pages visited, time spent on pages, and referring website.
We may use third-party analytics service providers that use cookies and similar technologies to help us understand how visitors interact with our website. The information collected through these technologies is used solely for analytics and site improvement purposes. We do not use cookies or similar technologies for behavioral advertising or cross-site marketing.
Some cookies are necessary for the website to function properly. Other analytics cookies are not strictly necessary but help us evaluate and improve the site. You may manage or disable cookies through your browser settings. Disabling certain cookies may affect the functionality of the website.
When you complete our Contact form, we collect the information you provide, which may include:
Individual Client Information
We collect personal information necessary to provide advisory services, coordinate financial planning, meet regulatory requirements, and improve our services. Information you provide to us includes:
Workplace Client Information
For individuals who participate in employer-sponsored benefit plans or workplace programs that we support, such as retirement plans or health savings accounts, we may collect and process personal information necessary to provide advisory, education, and administrative support services.
Depending on the nature of the workplace plan and the services provided, this information may include:
Cookies are small pieces of data that are stored on your computer, mobile device, or other device used to access the internet. Pixels and similar technologies are small blocks of code on a website that allow information to be collected about how visitors use the site.
We use cookies and similar technologies to operate our website, analyze website usage, and improve site performance and user experience. These technologies collect information such as browser type, device type, operating system, IP address, general geographic location, pages visited, time spent on pages, and referring website.
We may use third-party analytics service providers that use cookies and similar technologies to help us understand how visitors interact with our website. The information collected through these technologies is used solely for analytics and site improvement purposes. We do not use cookies or similar technologies for behavioral advertising or cross-site marketing.
Some cookies are necessary for the website to function properly. Other analytics cookies are not strictly necessary but help us evaluate and improve the site. You may manage or disable cookies through your browser settings. Disabling certain cookies may affect the functionality of the website.
When you complete our Contact form, we collect the information you provide, which may include:
- First and last name
- Email address
- Phone number
- Financial institution name
- Topic of interest
- Message content
Individual Client Information
We collect personal information necessary to provide advisory services, coordinate financial planning, meet regulatory requirements, and improve our services. Information you provide to us includes:
- Full legal name
- Email address
- Physical address
- Mailing address
- Telephone number
- Date of birth
- Social Security number or tax identification number
- Employment and income information
- Financial information such as assets, liabilities, investment objectives, and risk tolerance
- Account balances and transaction history
- Information about accounts held at other financial institutions
- Beneficiary and estate planning information
Workplace Client Information
For individuals who participate in employer-sponsored benefit plans or workplace programs that we support, such as retirement plans or health savings accounts, we may collect and process personal information necessary to provide advisory, education, and administrative support services.
Depending on the nature of the workplace plan and the services provided, this information may include:
- Full legal name
- Email address
- Physical or mailing address
- Telephone number
- Date of birth
- Social Security number or tax identification number
- Employment information, including employer name and job status
- Compensation information
- Plan account balances and transaction history
- Contribution amounts and investment elections
- Beneficiary designations
- Distribution or rollover information
How We Use Your Information
Polaris Financial uses personal information to provide investment advisory services and related financial planning support, operate our business, and comply with legal and regulatory requirements.
We may use your personal information to:
From time to time, we may aggregate or de-identify information for internal reporting, business analysis, or improvement of our services. When we do so, the information is processed in a manner that does not identify any individual client.
We may contact you regarding your accounts, inquiries, or services we provide. Certain communications related to account administration, regulatory requirements, disclosures, billing, or service updates are necessary and may not be optional.
If we are unable to reach you by email, we may attempt to contact you through other methods you have provided, such as telephone or mail, for purposes related to your account or inquiry.
We may use your personal information to:
- Provide investment advisory & financial planning services
- Open, maintain, and service advisory accounts
- Coordinate with custodians, plan administrators, and other authorized service providers
- Respond to inquiries and provide client support
- Communicate with you regarding your accounts, services, or requests
- Monitor and improve our services and website functionality
- Maintain internal records and business operations
- Detect, prevent, and respond to fraud, cybersecurity incidents, or other security concerns
- Comply with applicable federal and state laws, including regulatory, tax, and recordkeeping requirements
From time to time, we may aggregate or de-identify information for internal reporting, business analysis, or improvement of our services. When we do so, the information is processed in a manner that does not identify any individual client.
We may contact you regarding your accounts, inquiries, or services we provide. Certain communications related to account administration, regulatory requirements, disclosures, billing, or service updates are necessary and may not be optional.
If we are unable to reach you by email, we may attempt to contact you through other methods you have provided, such as telephone or mail, for purposes related to your account or inquiry.
How We Share Your Information
We share personal information only as necessary to provide advisory services, operate our business, and comply with legal and regulatory requirements.
We may share personal information with the following categories of service providers and business partners:
Polaris Financial partners with unaffiliated financial institutions to provide investment advisory and financial planning services to user, clients and/or members. In connection with these arrangements, we may share nonpublic personal information (“NPI”) with such financial institutions as described below.
Categories of information that may be shared:
Your rights: Because this sharing is conducted within the exceptions described above, federal law does not require us to provide you with the right to opt out of this sharing. However, you may contact us at [email protected] with questions about what information we have shared and with whom.
We may share personal information with the following categories of service providers and business partners:
- Broker-dealers and custodians. We share information with broker-dealers, custodians, and account service providers to open, maintain, and service investment accounts, process transactions, and provide account reporting.
- Portfolio management, trading, and reporting platforms. We use third-party technology platforms to support portfolio management, trading, performance reporting, financial planning, and client relationship management. These providers receive information necessary to perform services on our behalf.
- Compliance, legal, and professional advisors. We may share information with compliance consultants, legal counsel, auditors, and other professional advisors to help us meet regulatory obligations and operate our business.
Polaris Financial partners with unaffiliated financial institutions to provide investment advisory and financial planning services to user, clients and/or members. In connection with these arrangements, we may share nonpublic personal information (“NPI”) with such financial institutions as described below.
Categories of information that may be shared:
- Client identification information (name, address, contact information)
- Account information (account number, account type, account status)
- Transaction and holdings data (where required for account coordination)
- Referral source information
- To accept and respond to member referrals from financial institutions
- To coordinate service delivery for clients who are also members of a financial institution partner
- To provide account updates to a referring financial institution where required under a joint servicing arrangement
- To satisfy the terms of any written agreement between Polaris Financial and the financial institution governing the advisory relationship
Your rights: Because this sharing is conducted within the exceptions described above, federal law does not require us to provide you with the right to opt out of this sharing. However, you may contact us at [email protected] with questions about what information we have shared and with whom.
Information Sharing Practices
Your Privacy Rights
Federal law provides consumers with certain rights regarding the sharing of NPI. In general, financial institutions may share personal information as necessary to provide services, maintain accounts, and comply with legal and regulatory requirements.
Under federal law, you may have the right to limit certain types of information sharing in specific circumstances. However, because we share information only as permitted by law and solely to provide advisory services, operate our business, and comply with regulatory obligations, many of these opt out rights may not apply to our practices.
Depending on your state of residence, you may have additional privacy rights, which may include the right to request access to personal information we maintain about you, request correction of inaccurate information, or request deletion of personal information, subject to applicable legal and regulatory limitations.
Massachusetts Residents have the right to:
Under federal law, you may have the right to limit certain types of information sharing in specific circumstances. However, because we share information only as permitted by law and solely to provide advisory services, operate our business, and comply with regulatory obligations, many of these opt out rights may not apply to our practices.
Depending on your state of residence, you may have additional privacy rights, which may include the right to request access to personal information we maintain about you, request correction of inaccurate information, or request deletion of personal information, subject to applicable legal and regulatory limitations.
Massachusetts Residents have the right to:
- Request access to personal information we maintain about you
- Request correction of inaccurate personal information
- Request deletion of personal information, subject to legal and regulatory limitations on our ability to delete records we are required to retain
- Receive notice of a security breach involving your personal information as expeditiously as possible
Data Security
We maintain administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, alteration, or disclosure.
These safeguards include access controls, secure authentication procedures, encryption of sensitive data where appropriate, secure data storage, network security measures, employee training, and policies governing the handling and protection of personal information. We also maintain physical security measures to protect our offices and systems.
We engage third-party technology vendors and service providers who are required to maintain appropriate security controls and safeguards consistent with applicable legal and regulatory requirements. We take reasonable steps to evaluate and monitor the security practices of these providers.
While we implement safeguards designed to protect personal information, no method of transmission over the internet or electronic storage is completely secure. Accordingly, we cannot guarantee absolute security.
Incident Response Program
Polaris Financial maintains a written incident response program designed to detect, respond to, and recover from unauthorized access to or use of customer information. Our incident response program includes procedures to:
In the event we determine that sensitive customer information has been or is reasonably likely to have been accessed or used without authorization, we will provide notice to affected individuals as soon as practicable, and in no event later than 30 days after becoming aware of the incident, unless a law enforcement authority has requested a delay. This requirement is consistent with the May 2024 amendments to SEC Regulation S-P (17 C.F.R. Part 248).
Such notice will include: (1) a description of the incident; (2) the type of sensitive customer information that was or may have been accessed; (3) contact information for Polaris Financial so that affected individuals may ask questions or obtain further information; and (4) information about steps affected individuals can take to protect themselves.
"Sensitive customer information" includes, but is not limited to: Social Security numbers, account numbers in combination with passwords or security codes, government-issued identification numbers, and other information that, alone or in combination, could create a reasonably likely risk of harm if compromised.
Massachusetts Residents: In addition to the above, Polaris Financial will notify the Massachusetts Office of Consumer Affairs and Business Regulation and affected Massachusetts residents of any security breach involving their personal information (as defined under M.G.L. c. 93H) as expeditiously as possible and without unreasonable delay, consistent with the legitimate needs of law enforcement.
These safeguards include access controls, secure authentication procedures, encryption of sensitive data where appropriate, secure data storage, network security measures, employee training, and policies governing the handling and protection of personal information. We also maintain physical security measures to protect our offices and systems.
We engage third-party technology vendors and service providers who are required to maintain appropriate security controls and safeguards consistent with applicable legal and regulatory requirements. We take reasonable steps to evaluate and monitor the security practices of these providers.
While we implement safeguards designed to protect personal information, no method of transmission over the internet or electronic storage is completely secure. Accordingly, we cannot guarantee absolute security.
Incident Response Program
Polaris Financial maintains a written incident response program designed to detect, respond to, and recover from unauthorized access to or use of customer information. Our incident response program includes procedures to:
- Assess the nature and scope of any security incident involving customer information;
- Take appropriate steps to contain and control any such incident to prevent further unauthorized access or use;
- Evaluate whether sensitive customer information has been or is reasonably likely to have been compromised;
- Oversee service providers with access to customer information, including contractual requirements that service providers notify us within 72 hours of becoming aware of a security breach affecting customer information maintained on our behalf; and
- Notify affected individuals and applicable regulatory authorities as required by law.
In the event we determine that sensitive customer information has been or is reasonably likely to have been accessed or used without authorization, we will provide notice to affected individuals as soon as practicable, and in no event later than 30 days after becoming aware of the incident, unless a law enforcement authority has requested a delay. This requirement is consistent with the May 2024 amendments to SEC Regulation S-P (17 C.F.R. Part 248).
Such notice will include: (1) a description of the incident; (2) the type of sensitive customer information that was or may have been accessed; (3) contact information for Polaris Financial so that affected individuals may ask questions or obtain further information; and (4) information about steps affected individuals can take to protect themselves.
"Sensitive customer information" includes, but is not limited to: Social Security numbers, account numbers in combination with passwords or security codes, government-issued identification numbers, and other information that, alone or in combination, could create a reasonably likely risk of harm if compromised.
Massachusetts Residents: In addition to the above, Polaris Financial will notify the Massachusetts Office of Consumer Affairs and Business Regulation and affected Massachusetts residents of any security breach involving their personal information (as defined under M.G.L. c. 93H) as expeditiously as possible and without unreasonable delay, consistent with the legitimate needs of law enforcement.
Information Security Program
We maintain a comprehensive written information security program ("WISP") consistent with the requirements of Massachusetts 201 CMR 17.00 and the GLBA Safeguards Rule. Our program includes:
- Designation of a qualified individual responsible for overseeing and implementing our information security program
- Risk assessment processes to identify internal and external risks to the security of customer information
- Administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, modification, or disclosure
- Employee training on data security and privacy obligations
- Vendor management procedures, including contractual requirements for service providers to maintain appropriate safeguards
- Regular monitoring, testing, and evaluation of our security controls
- An incident response program as described above
Annual Privacy Notice
Federal law requires that we provide you with a privacy notice at the time we establish a customer relationship and, in some circumstances, annually thereafter. We are not required to deliver an annual privacy notice to existing clients if we share nonpublic personal information only within the exceptions provided by federal law (15 U.S.C. §6802(e)) and our privacy practices have not changed since our last notice. If we change our privacy practices in a way that requires us to provide an annual notice, we will do so. You may request a copy of our current Privacy Policy at any time by contacting us at [email protected] .
Contact Information
If you have any questions on the privacy policy, please contact us at:
Polaris Financial LLC
Address: 6 Liberty Square #2663 Boston, MA 02109
Phone: (888) 212-9940
Email: [email protected]
Polaris Financial LLC
Address: 6 Liberty Square #2663 Boston, MA 02109
Phone: (888) 212-9940
Email: [email protected]