Privacy Policy

INTRODUCTION

The Lutz Companies (as defined below) respect your privacy, and we are committed to protecting it through our compliance with this policy. The Lutz Companies (“Lutz”, “we”, “our” or “us”) refers to companies or brands using the Lutz name, including, without limitation, Lutz & Company, P.C., Lutz Technology, LLC and Lutz Financial, LLC.

This policy describes the types of information we may collect or that you may provide when we conduct our business or when you visit our website at: https://www.lutz.us (our “Website“) and our practices for collecting, using, maintaining, protecting, and disclosing that information. Please read this Privacy Policy in conjunction with the Lutz Privacy Notice, provided pursuant to the Gramm-Leach-Bliley Act and the Securities and Exchange Commission’s (“SEC”) Privacy of Consumer Financial Information Rule (“Regulation S-P”) and the CCPA Privacy Notice, provided pursuant to the California Consumer Privacy Act of 2018. We will never sell or share the nonpublic personal information[1] obtained from or in reference to clients. All information provided by clients to Lutz and its staff, and information and advice furnished to clients by us, shall be treated as confidential and shall not be disclosed to affiliated or unaffiliated third parties, except as permitted or directed by clients with written authorization, by application to facilitate the services offered by us via an unaffiliated services provider, or as required by any rule, regulation or law.

COMMITMENT TO YOUR PRIVATE INFORMATION

Lutz is committed to safeguarding the confidential information of its clients. We hold all personal information provided by clients in the strictest confidence and it is the objective of the firm to protect the privacy of all clients.  Except as permitted or required by law, Lutz does not share confidential information about clients with nonaffiliated parties. It is our policy to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services in furtherance of the client’s engagement of Lutz. We permit only authorized employees and affiliates who have acknowledged receipt and understanding of our Privacy Policy by acknowledging and accepting our policies and procedures to have access to client information. Employees violating our Privacy Policy will be subject to our disciplinary process. If there are any changes to this policy, we will provide clients with written notice.

This policy applies to the information we collect:

• On this Website;
• In email, text, and other electronic messages between you and this Website;
• Through mobile and desktop applications you download from this Website, which provides dedicated non-browser-based interaction between you and this Website;

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then you should not use our Website, purchase our products or receive our services. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website, continued purchase of our products or continued receipt of our services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

CHILDREN UNDER THE AGE OF 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@lutz.us.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or
• That is about you but individually does not identify you; and/or
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us;
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies;
• From your employer, with respect to employer-sponsored plans;
• From third parties, for example, our business partners, non-affiliated third parties and service providers;
• We may also collect information on your employment history; and
• From your transactions with us or our service providers

INFORMATION YOU PROVIDE TO US

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our services, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us and when you report a problem with our
• Records and copies of your correspondence (including email addresses) if you contact us.
• Your responses to surveys that we might ask you to complete for research
• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our
• Your search queries on the Website.

As you navigate through and interact with our Website, we may use automatic data collection technologies or “cookies” to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data, and the resources that you access and use on the
• Information about your computer and internet connection, including your IP address, operating system, and browser

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. For more information, please see our Cookie Policy.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We do not collect personal information automatically, but we may aggregate this information with personal information about you that we collect from other sources or you provide to us.

THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Some content or applications, including advertisements, on the Website are served by third- parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to
• To provide you with information, products, or services that you request from
• To fulfill any other purpose for which you provide
• To notify you about changes to our Website or any products or services we offer or provide though
• To allow you to participate in interactive features on our
• For any other purpose with your consent.

We may also use your information to contact you about our own goods and services that may be of interest to you. If you do not want us to use your information in this way, please send an email to us with your request to privacy@lutz.us. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates;
• To contractors, service providers, and other third parties we use to support our business;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred;
• To fulfill the purpose for which you provide For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients;
• As otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations
• For any other purpose disclosed by us when you provide the information; and
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email with your request to privacy@lutz.us.
• Promotional Offers from If you do not wish to have your contact information used by us to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to privacy@lutz.us. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

ACCESSING AND CORRECTING YOUR INFORMATION

You may also send us an email at privacy@lutz.us to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

CALLS AND TEXTS

When you request assistance with your computer from our tech team, we will send a text or place a call to the phone number you have provided in order to receive your authorization for our tech team to remotely access your computer. We will not send marketing texts or place marketing calls to your phone number.

By providing your phone number, you consent to receive calls and texts from Lutz as described in this section. We will not share your phone number with third parties, except for our service providers who are subject to security and confidentiality requirements. Your phone number will be stored securely in accordance with our data protection policies and procedures. All calls and texts will comply with applicable laws and regulations, including the Telephone Consumer Protection Act. You can reply “STOP” to any message to opt out of text messages from Lutz.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit our CCPA Privacy Notice.

DATA SECURITY

Lutz maintains physical, electronic, and procedural safeguards that comply with federal standards to protect your nonpublic personal information. We have implemented measures designed to secure and protect your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls and access to your records are only granted to authorized persons of the firm who have a need to access your personal information in order to assist Lutz in delivering the services you have consented or respond to client requests. Any payment transactions will be encrypted.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website or when you link to third party websites from our Website. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website.

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting our Website and this privacy policy to check for any changes.

CONTACT INFORMATION

To ask questions or comment about this privacy policy and our privacy practices, contact us via email at privacy@lutz.us or via phone at 866-577-0780.

[1] The Gramm-Leach-Bliley Act protects nonpublic personal information, defined as personally identifiable financial information collected about an individual in connection with a financial product or service. Information that is generally publicly available is not covered by the law. Under the CCPA, Personal Information includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.