Privacy Policy

Introduction

Harvest Lane Investment Partners LLC (“HLIP,” “we,” “our,” or “the Firm”) is committed to safeguarding the nonpublic personal information of our clients and prospective clients. This Privacy Policy Notice is provided in accordance with Regulation S-P (17 CFR Part 248) under the Gramm-Leach-Bliley Act and applicable state privacy laws, and describes how we collect, use, maintain, and protect your personal information.

We are required by law to provide this notice to you at the time of establishing an advisory relationship, annually thereafter, and at any time our privacy practices materially change.

Information We Collect

In the course of providing investment advisory services, we may collect the following categories of nonpublic personal information about you:

• Information you provide directly, including your name, address, date of birth, Social Security number or tax identification number, telephone number, email address, employment and income information, financial account information, net worth, investment objectives, risk tolerance, tax information, and estate planning information.
• Information from your transactions with us or others, including account balances, securities holdings, transaction history, payment history, and account activity.
• Information from third parties, including information from custodians, broker-dealers, account aggregation services, credit reporting agencies (if applicable), and other financial institutions involved in servicing your accounts.

How We Use Your Information

We use your nonpublic personal information to:

• Provide investment advisory and financial planning services
• Open, administer, and manage your accounts
• Process transactions and maintain accurate records
• Comply with legal and regulatory requirements
• Communicate with you about your accounts and services
• Detect and prevent fraud or unauthorized activity

We do not sell your nonpublic personal information to any third party for any purpose.

Information We Disclose

We do not disclose nonpublic personal information about our clients or former clients to any nonaffiliated third party, except as permitted or required by law. Disclosures permitted by law include sharing information:

• With service providers who assist us in administering and servicing your accounts (such as our qualified custodian, Altruist Financial LLC; technology providers; and compliance consultants), provided they agree to maintain the confidentiality of such information and use it only for the purpose for which it was disclosed
• As necessary to effect, administer, or enforce a transaction that you request or authorize
• With your written consent
• To comply with federal, state, or local laws, rules, or regulations, including responding to a subpoena, court order, or regulatory inquiry
• To protect against fraud or unauthorized transactions
• To law enforcement agencies when we believe it is necessary to prevent or report suspected illegal activity

Because we do not disclose nonpublic personal information to nonaffiliated third parties other than as described above, we are not required to provide you with an opportunity to opt out of such disclosures.

Former Clients

We do not disclose nonpublic personal information about former clients, except as permitted or required by law, as described above.

Website Analytics & Visitor Identification

When you visit our website, we and our third-party service providers automatically collect certain technical information through cookies, pixels, tags, and similar technologies. This information is separate from the nonpublic personal information described above and may include:

• Your Internet Protocol (IP) address, general geographic location, and the organization or business associated with your network
• Browser type, device characteristics, operating system, and the website that referred you
• Pages viewed, links clicked, time spent on the site, and similar usage activity

We use this information to understand how visitors engage with our website, to improve our content, and to identify businesses and prospective clients who may benefit from our services so that we may follow up with them. For these purposes we use third-party website analytics and visitor-identification services that may resolve a visitor’s IP address to the company or organization associated with it. These providers process information in accordance with their own privacy policies.

This activity concerns website visitors and is separate from our handling of client and prospective-client nonpublic personal information. We do not sell your nonpublic personal information, and we do not permit these providers to use the information they collect for any purpose other than providing services to us.

You can limit much of this collection by adjusting your browser settings to refuse or delete cookies, by enabling a “Do Not Track” or Global Privacy Control signal, or by using browser privacy tools. If you have questions or requests regarding website data, please contact us using the information below.

Text Messaging (SMS)

If you provide your mobile telephone number and consent to receive text (SMS) messages from us — for example, in your advisory agreement at onboarding — we use it to communicate with you about appointment scheduling, document requests, account and service updates, and replies to your questions. Message frequency varies, and message and data rates may apply through your wireless carrier.

No mobile information — including your mobile phone number and your consent to receive text messages — will be sold, rented, or shared with any third parties or affiliates for their own marketing or promotional purposes. Information you provide in connection with the text-messaging program is used solely to operate that program and is otherwise handled in accordance with this Privacy Policy.

You may opt out of text messages at any time by replying STOP, and reply HELP for assistance. Opting out of texts does not end your advisory relationship or affect other ways we communicate with you. Full terms are described in our Text Messaging Terms.

Confidentiality and Security

We maintain physical, electronic, and procedural safeguards to protect your nonpublic personal information. These safeguards include:

• Restricting access to your personal information to supervised persons who need the information to provide services to you
• Maintaining secure electronic systems with encryption, multi-factor authentication, and access controls
• Using secure methods for the transmission and storage of client data
• Requiring service providers who have access to your information to maintain appropriate security measures
• Maintaining a cybersecurity program that includes risk assessments, incident response procedures, and employee training
• Disposing of client records in a secure manner when they are no longer required to be maintained

Our cybersecurity and data protection practices are described in greater detail in the Firm’s Compliance Policies and Procedures Manual.

Changes to This Policy

If we make material changes to our privacy practices, we will provide you with a revised Privacy Policy Notice. We will deliver our Privacy Policy Notice to you annually, as required by law.

Questions

If you have questions about this Privacy Policy Notice or our privacy practices, please contact: