1. Introduction and Scope

This Privacy Policy (“Policy”) describes how Neil Jesani Advisors, Inc. (“NJA,” “we,” “us,” or “our”), a Securities and Exchange Commission (SEC) registered investment advisor, collects, uses, discloses, stores, and protects the personal information of visitors to our website (neiljesani.com), users of our digital services, prospective clients, current clients, and former clients (collectively, “you” or “your”). This Policy applies to all information collected through our website, mobile applications, email communications, electronic forms, social media interactions, telephone communications, in-person meetings, and any other means through which you provide information to us or we collect information about you.

By accessing or using our website, submitting information through any of our forms, engaging our advisory services, or otherwise interacting with us, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with any provision of this Policy, you must immediately discontinue use of our website and services.

2. Information We Collect

2.1 Personally Identifiable Information (PII)

We may collect the following categories of personally identifiable information: full legal name; email address; telephone number(s) including mobile, home, and business; physical mailing address; date of birth; Social Security number or Tax Identification Number (for advisory clients); employment information including employer name, title, and compensation; financial information including income, net worth, investable assets, account balances, tax returns, and investment holdings; banking and brokerage account information; government-issued identification documents; marital and family status; estate planning documents; insurance policy information; beneficiary designations; risk tolerance and investment objectives; and any other information you voluntarily provide to us.

2.2 Non-Personally Identifiable Information (Non-PII)

We automatically collect certain non-personally identifiable information when you visit our website, including but not limited to: Internet Protocol (IP) address; browser type, version, and language; operating system and device type; referring URL and exit pages; pages viewed, time spent on pages, and navigation paths; date, time, and duration of visits; geographic location data (city/region level); click-stream data and interaction patterns; and cookies, pixel tags, web beacons, and similar tracking technologies.

2.3 Information from Third Parties

We may receive information about you from third-party sources including custodians, broker-dealers, financial institutions, credit reporting agencies, identity verification services, public records databases, professional networking platforms, referral sources, and other service providers with whom we maintain business relationships.

3. How We Use Your Information

We use the information we collect for the following purposes: to provide, maintain, and improve our investment advisory and wealth management services; to process and respond to your inquiries, requests, and form submissions; to communicate with you regarding your account, our services, market updates, and educational content; to comply with our fiduciary obligations and regulatory requirements as an SEC-registered investment advisor; to verify your identity and prevent fraud, money laundering, and other illegal activities; to perform account administration, billing, and internal record-keeping; to conduct due diligence, suitability assessments, and know-your-customer (KYC) reviews; to customize and personalize your experience on our website; to analyze website usage, trends, and effectiveness of our marketing efforts; to send you marketing communications about our services, subject to your opt-out preferences; to enforce our Terms of Use, this Privacy Policy, and other agreements; to comply with applicable laws, regulations, court orders, subpoenas, and government requests; to protect our rights, property, safety, and those of our clients, employees, and the public; and for any other purpose disclosed to you at the time of collection with your consent.

4. Cookies and Tracking Technologies

Our website uses cookies, pixel tags, web beacons, local storage, and similar technologies to collect and store information about your interactions with our website. Cookies are small data files stored on your device that help us recognize you, remember your preferences, and understand how you use our website.

We use the following types of cookies: Essential cookies that are necessary for the website to function properly and cannot be disabled; Analytics cookies that help us understand how visitors interact with our website by collecting usage data anonymously; Functional cookies that remember your preferences and choices to provide a personalized experience; and Marketing cookies that track your activity across websites to deliver targeted advertising relevant to you.

You may control or disable cookies through your browser settings. However, disabling certain cookies may limit your ability to use some features of our website. By continuing to use our website without adjusting your cookie settings, you consent to our use of cookies as described in this Policy.

5. Disclosure of Information

We do not sell, rent, lease, or trade your personal information to third parties for their marketing purposes. We may disclose your personal information in the following circumstances:

Service Providers: We may share your information with trusted third-party service providers who assist us in operating our business, including but not limited to: custodians (e.g., Charles Schwab, Fidelity); technology and software providers; email service providers; website hosting and analytics providers; compliance and regulatory technology providers; accounting and auditing firms; legal counsel; and cybersecurity consultants. These service providers are contractually obligated to use your information solely for the purposes of providing services to us and are required to maintain the confidentiality of your information.
Legal and Regulatory: We may disclose your information as required by applicable law, regulation, legal process, or governmental request, including but not limited to: SEC examinations and investigations; FINRA inquiries; state securities regulatory requests; court orders and subpoenas; tax reporting requirements (IRS, state tax authorities); anti-money laundering (AML) compliance; and Bank Secrecy Act reporting obligations.
Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, dissolution, sale of assets, or other business transition, your personal information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.
With Your Consent: We may share your information with third parties when you have given us your express or implied consent to do so, including when you direct us to coordinate with your other professional advisors (attorneys, CPAs, insurance agents).

6. Data Security

We implement comprehensive administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, use, alteration, disclosure, or destruction. Our security measures include but are not limited to: encryption of data in transit (TLS/SSL) and at rest (AES-256); multi-factor authentication for system access; role-based access controls limiting information access to authorized personnel on a need-to-know basis; firewalls, intrusion detection systems, and network monitoring; regular vulnerability assessments and penetration testing; employee security awareness training; vendor security assessments and due diligence; physical security controls at our offices including access badges and surveillance; secure document destruction and data disposal procedures; incident response and business continuity plans; and regular review and updating of security policies and procedures.

While we strive to protect your personal information, no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee absolute security of your data. You acknowledge and accept this inherent risk when providing information to us electronically.

7. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, comply with our legal and regulatory obligations, resolve disputes, enforce our agreements, and as required by our records retention policies. For current and former advisory clients, we retain account records and related personal information for a minimum of five (5) years following the termination of the advisory relationship, or longer as required by SEC regulations (Rule 204-2 under the Investment Advisers Act of 1940), state securities laws, tax laws, and other applicable regulations. Non-client inquiry data submitted through website forms is retained for a minimum of three (3) years. Website analytics data is retained in aggregate form indefinitely.

8. Your Rights and Choices

Subject to applicable law, you have the following rights regarding your personal information:

Right to Access: You may request a copy of the personal information we hold about you.
Right to Correction: You may request that we correct inaccurate or incomplete personal information.
Right to Deletion: You may request that we delete your personal information, subject to our legal and regulatory retention obligations.
Right to Restrict Processing: You may request that we limit the processing of your personal information in certain circumstances.
Right to Data Portability: You may request that we provide your personal information in a structured, commonly used, machine-readable format.
Right to Object: You may object to the processing of your personal information for direct marketing purposes.
Right to Opt-Out of Marketing: You may opt out of receiving marketing communications from us at any time by clicking the “unsubscribe” link in our emails or by contacting us directly.

To exercise any of these rights, please contact us using the information provided at the end of this Policy. We will respond to your request within thirty (30) days, or such other timeframe as required by applicable law. We may require you to verify your identity before processing your request.

9. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), including the right to know what personal information we collect, use, disclose, and sell; the right to delete personal information; the right to opt out of the sale or sharing of personal information; the right to correct inaccurate personal information; the right to limit use of sensitive personal information; and the right to non-discrimination for exercising your privacy rights. We do not sell personal information as defined under the CCPA/CPRA. To exercise your California privacy rights, please contact us using the information below. We will verify your identity using the information associated with your account or request.

10. Gramm-Leach-Bliley Act Compliance

As an SEC-registered investment advisor, we are subject to Regulation S-P (Privacy of Consumer Financial Information) under the Gramm-Leach-Bliley Act (GLBA). We provide our clients with an initial privacy notice upon establishing a client relationship and annual privacy notices thereafter, as required by Regulation S-P. Our GLBA privacy notice describes the categories of nonpublic personal information we collect, the categories of third parties with whom we share such information, and our policies for protecting nonpublic personal information. Clients may receive our full Regulation S-P privacy notice by contacting us directly.

11. Children’s Privacy

Our website and services are not directed to individuals under the age of eighteen (18). We do not knowingly collect personal information from children under 18. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete such information promptly. If you believe we have collected information from a child under 18, please contact us immediately.

12. Third-Party Links and Services

Our website may contain links to third-party websites, services, and applications that are not owned or controlled by us, including custodian portals, financial planning tools, scheduling services, and social media platforms. This Privacy Policy applies only to our website and services. We are not responsible for the privacy practices, content, or security of any third-party websites or services. We encourage you to review the privacy policies of any third-party websites you visit.

13. Mobile and Text Message Privacy

If you opt in to receive text messages or SMS communications from us, we will use your mobile phone number solely for the purpose of sending you the communications you have requested. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All categories exclude text messaging originator opt-in data and consent. You will receive approximately 2 messages a month. Message frequency may vary. Message and data rates may apply. You may opt out of text messages at any time by replying STOP to any message.

14. Do Not Track Signals

Some browsers offer a “Do Not Track” (“DNT”) feature that sends a signal to websites you visit indicating you do not want to be tracked. There is no universally accepted standard for how to respond to DNT signals. At this time, our website does not respond to DNT signals. However, you can manage your tracking preferences through your browser cookie settings as described in Section 4 of this Policy.

15. International Users

Our website and services are operated in and directed to users in the United States. If you access our website or provide personal information to us from outside the United States, you understand and consent to the collection, transfer, storage, and processing of your information in the United States, where data protection laws may differ from those in your jurisdiction. We do not target or market our services to individuals located in the European Economic Area (EEA), United Kingdom, or other jurisdictions outside the United States.

16. Data Breach Notification

In the event of a data breach involving your personally identifiable information, we will comply with all applicable federal and state breach notification laws. We will notify affected individuals within the timeframes required by applicable law, which may include notification within thirty (30) to sixty (60) days of discovery depending on the jurisdiction. Notification may be provided electronically, by mail, by telephone, or through substitute notice as permitted by law. We maintain a written incident response plan that includes procedures for detecting, investigating, containing, and remediating security incidents.

17. Changes to This Privacy Policy

We reserve the right to modify, amend, or update this Privacy Policy at any time and for any reason. Any changes will be effective immediately upon posting the revised Policy on our website with the updated “Last Updated” date. Your continued use of our website or services after the posting of any changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically. For material changes that significantly affect how we use or share your personal information, we will make reasonable efforts to provide notice, such as through a prominent posting on our website or by email notification.

18. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy, your personal information, or our privacy practices, please contact us at:

Neil Jesani Advisors, Inc.
1301 International Parkway, Suite 550
Sunrise, FL 33323
Phone: (800) 758-3101
Email: hello@neiljesani.com