CCPA

Last Updated: July 24, 2026

If you are a person residing in California, then you (“you” and “your”) are a California consumer, and this California Consumer Privacy Policy (“Policy”) applies to you. This Policy describes the privacy rights that may be available under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), and explains how you may exercise those rights.

“Global Advisers,” “we,” “us,” and “our” refer to Global Advisers, LLC.

This Policy supplements our general Privacy Policy and applies only to personal information governed by the CCPA. If another privacy notice applies more specifically to particular information or services, the more specific notice governs to the extent of any conflict.

A. THE CCPA AND FINANCIAL INFORMATION

Personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California consumer or household. Personal information does not include publicly available, deidentified, or aggregated information, as those terms are defined by applicable law.

Global Advisers may not meet the statutory definition of a covered “business” under the CCPA in every year or circumstance. To the extent Global Advisers is subject to the CCPA with respect to particular personal information, the disclosures and rights described in this Policy apply, subject to applicable limitations and exemptions.

The CCPA generally does not apply to personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (“GLBA”) or the California Financial Information Privacy Act. This generally includes information we collect from you when you obtain or seek to obtain investment advisory or other financial services from us.

Accordingly, most personal information maintained about clients and prospective clients in connection with investment advisory services may not be governed by the CCPA. Requests concerning information subject to the GLBA, securities recordkeeping requirements, or another applicable exemption may be denied or limited as permitted by law.

B. PERSONAL INFORMATION WE MAY COLLECT

Depending on your interaction with us, we may collect the following categories of personal information:

Identifiers

• Name;
• Postal address;
• Email address;
• Telephone number;
• Internet Protocol address;
• Online identifiers; and
• Other similar identifiers.

We may collect identifiers directly from you through website forms, email, telephone, text messages, meeting requests, newsletter subscriptions, cookies, and similar technologies. We may also receive identifiers from service providers, referral sources, operating systems, platforms, and publicly available sources.

California Customer Records Information

• Name;
• Postal address;
• Telephone number;
• Email address; and
• Other contact information.

Commercial Information

• Services obtained or considered;
• Areas of expressed interest;
• Client or prospective-client relationship information; and
• Records of interactions with Global Advisers.

Internet or Other Electronic Network Activity

• Website pages viewed;
• Links selected;
• Date and time of access;
• Referring website;
• Browser type;
• Device information;
• Operating-system information;
• Cookie identifiers;
• Interactions with our website or online communications; and
• Similar usage information.

Geolocation Data

We may collect general or approximate location information derived from your Internet Protocol address or similar technologies. We do not intentionally collect precise geolocation information through our public website unless specifically disclosed at the point of collection.

Professional or Employment-Related Information

• Occupation;
• Job title;
• Employer;
• Business ownership information;
• Professional credentials; and
• Business contact information.

Audio, Visual, or Similar Information

• Voicemail messages;
• Video-conference interactions;
• Photographs provided by you; and
• Call recordings where notice or consent has been provided as required by law.

Inferences

We may derive limited inferences from other personal information concerning communication preferences, service interests, website interests, or likely needs based on information you provide.

Sensitive Personal Information

In connection with investment advisory or financial-planning services, we may collect sensitive personal information, including Social Security or taxpayer identification numbers, government-issued identification information, financial-account information, account credentials, tax information, health or disability information relevant to financial planning, and information concerning dependents or beneficiaries.

Much of this information may be subject to the GLBA or another exemption from the CCPA. We use and disclose sensitive personal information only for purposes reasonably necessary to provide services, verify identity, protect accounts and systems, maintain records, comply with law, or perform other legally permitted functions. We do not use or disclose sensitive personal information for the purpose of inferring characteristics about California consumers.

C. SOURCES OF PERSONAL INFORMATION

We may collect personal information from:

• You directly;
• Your devices and browsers;
• Cookies and similar technologies;
• Website analytics providers;
• Account custodians and financial institutions;
• Technology, communications, and compliance service providers;
• Professional advisers and authorized representatives;
• Referral sources and business contacts;
• Operating systems and platforms; and
• Publicly available sources.

D. THIRD-PARTY COLLECTION OF PERSONAL INFORMATION ONLINE

We may permit service providers to collect internet or other electronic network activity information through our website. Third-party analytics, advertising, social-media, embedded-content, and other technology providers may collect information concerning consumers’ online activities over time and across different websites or online services.

Additional information regarding cookies, analytics, online tracking, browser signals, and available choices is provided in our Privacy Policy and through the cookie-preference mechanism displayed on our website.

E. HOW WE USE PERSONAL INFORMATION

We may use personal information for the following business and commercial purposes:

• To respond to inquiries and provide requested information;
• To manage client and prospective-client relationships;
• To provide investment advisory and financial-planning services;
• To schedule and conduct meetings;
• To send administrative, legal, regulatory, security, and service-related communications;
• To send newsletters, market commentary, firm announcements, and other marketing communications where permitted by law;
• To operate, maintain, analyze, and improve our website and technology;
• To measure the effectiveness of communications and outreach;
• To detect, prevent, and respond to fraud, unauthorized activity, and security incidents;
• To maintain business and regulatory records;
• To perform internal reporting, analytics, quality assurance, and business planning;
• To comply with applicable laws, regulations, legal process, and regulatory requests;
• To establish, exercise, or defend legal claims; and
• To protect the rights, property, and safety of Global Advisers, our clients, and others.

F. HOW WE DISCLOSE PERSONAL INFORMATION FOR BUSINESS OR COMMERCIAL PURPOSES

We may disclose personal information to the following categories of recipients, depending on the information involved and the purpose of the disclosure:

Service Providers and Processors

• Website-hosting providers;
• Information-technology and cybersecurity providers;
• Cloud-storage and document-management providers;
• Client-relationship-management providers;
• Portfolio-accounting and financial-planning providers;
• Email, telephone, text-message, and other communications providers;
• Analytics providers;
• Electronic-signature providers;
• Compliance, legal, accounting, and recordkeeping providers; and
• Other vendors providing operational support.

Financial Institutions and Authorized Professionals

• Account custodians;
• Broker-dealers;
• Financial institutions;
• Attorneys;
• Accountants;
• Insurance professionals;
• Trustees;
• Agents under powers of attorney;
• Family members or beneficiaries authorized by you; and
• Other professional advisers or authorized representatives.

Government, Regulatory, and Legal Authorities

We may disclose personal information to securities regulators, tax authorities, courts, law-enforcement agencies, government agencies, and other authorities when legally required or reasonably necessary to protect rights, property, or safety.

Business Transactions

We may disclose personal information in connection with a proposed or completed merger, acquisition, financing, reorganization, transfer of client relationships, sale of assets, or similar business transaction, subject to applicable legal and confidentiality requirements.

At Your Direction or With Your Authorization

We may disclose personal information when you direct, request, authorize, or consent to the disclosure.

G. PERSONAL INFORMATION WE MAY SELL OR SHARE

Global Advisers does not sell personal information in exchange for money.

Certain analytics, advertising, social-media, or embedded-content technologies may transmit identifiers, internet or other electronic network activity information, general geolocation data, commercial information, or inferences to third parties. Depending on how those technologies are configured and used, such disclosures may be considered a “sale” or “sharing” under the CCPA even when no money is exchanged.

To the extent our use of those technologies constitutes a sale or sharing under the CCPA, the categories of personal information involved may include:

• Identifiers;
• California Customer Records information;
• Commercial information;
• Internet or other electronic network activity information;
• General geolocation data; and
• Inferences.

We do not knowingly sell or share the personal information of consumers under 16 years of age.

H. RETENTION OF PERSONAL INFORMATION

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected or used, or as otherwise permitted or required by applicable law.

In determining retention periods, we consider:

• The purpose for which the information was collected;
• The nature and sensitivity of the information;
• The relationship involved;
• Legal, regulatory, contractual, and recordkeeping requirements;
• Whether the information is necessary to provide services;
• Whether retention is necessary to establish, exercise, or defend legal claims;
• Whether the information is subject to an examination, investigation, litigation hold, or similar obligation; and
• Security, fraud-prevention, and business-continuity considerations.

Investment-advisory records may be retained for the periods required by applicable securities laws and regulations. In some cases, we may retain information in a deidentified or aggregated form where it can no longer reasonably be associated with an identifiable consumer.

I. YOUR RIGHTS UNDER THE CCPA

To the extent the CCPA applies to Global Advisers and the personal information involved, you may have the following rights:

Right to Know and Access

You may request information concerning:

• The categories of personal information we collected about you;
• The categories of sources from which the information was collected;
• The business or commercial purposes for collecting, selling, or sharing the information;
• The categories of third parties to whom we disclosed the information;
• The categories of personal information sold or shared, if any;
• The categories of personal information disclosed for a business purpose; and
• The specific pieces of personal information we collected about you.

Right to Delete

You may request deletion of personal information we collected from you, subject to applicable exceptions. We may retain information where necessary to provide services, complete transactions, maintain investment-advisory records, detect or prevent fraud and security incidents, comply with law, establish or defend legal claims, maintain records of privacy requests, or otherwise use the information as permitted by law.

Right to Correct

You may request correction of inaccurate personal information we maintain about you.

Right to Opt Out of Sale or Sharing

You may opt out of the sale of your personal information or the sharing of personal information for cross-context behavioral advertising.

Right to Limit Use and Disclosure of Sensitive Personal Information

Where our use or disclosure of sensitive personal information creates a right to limit under the CCPA, you may direct us to limit that use or disclosure. Global Advisers generally uses sensitive personal information only for purposes reasonably necessary to provide financial services, verify identity, secure accounts and systems, maintain records, comply with law, and perform other legally permitted functions.

Right to Non-Discrimination

We will not unlawfully discriminate or retaliate against you for exercising an applicable CCPA right.

J. HOW TO SUBMIT A PRIVACY REQUEST

To exercise a right to know, access, delete, or correct, you may contact us through either of the following methods:

Email: corporate@globaladvisers.com
Telephone: 800-832-8514

Please identify your communication as a California Privacy Request and describe the right you wish to exercise.

To opt out of the sale or sharing of personal information through cookies or similar technologies, use the Your Privacy Choices, Do Not Sell or Share My Personal Information, or cookie-preference mechanism displayed on our website, where available.

Authorized Agents

An authorized agent may submit a request on your behalf where permitted by law. We may require the agent to provide proof of authority, including written permission signed by you. We may also require you to verify your identity directly or confirm that you authorized the agent to submit the request.

K. HOW WE VERIFY REQUESTS

Before responding to a request to know, access, delete, or correct, we may take reasonable steps to verify your identity or authority and confirm that the personal information relates to you.

Verification may include:

• Requesting information that can be matched against our records;
• Contacting you through an email address or telephone number already associated with you;
• Requesting confirmation through an existing client relationship or account;
• Requesting proof of California residency where relevant;
• Requesting proof of an authorized agent’s authority; or
• Requesting a signed declaration where permitted by law.

You are not required to create an account solely to submit a privacy request.

We may deny or limit a request if we cannot reasonably verify it, an exception applies, the information is not governed by the CCPA, or fulfilling the request would conflict with applicable law or regulatory obligations.

We will maintain records of CCPA requests and our responses for the period required by applicable law.

L. OPT-OUT PREFERENCE SIGNALS

An opt-out preference signal allows a consumer to communicate a browser- or device-based request to opt out of the sale or sharing of personal information.

Where Global Advisers is legally required to recognize an opt-out preference signal, and where our website is technically capable of detecting it, we will process a legally recognized signal, such as Global Privacy Control (“GPC”), as a request to opt out of sale or sharing for the browser or device from which the signal is sent.

Your preference may apply only to the browser, device, or profile from which the signal is transmitted. Our website may not respond to traditional “Do Not Track” signals, which are distinct from legally recognized opt-out preference signals.

M. CHANGES TO THIS POLICY

We may update this Policy periodically to reflect changes in our information practices, website technologies, services, vendors, legal requirements, regulatory requirements, or business operations.

When we revise this Policy, we will update the Last Updated date at the top. Where appropriate or legally required, we may provide additional notice of material changes.

N. CONTACT INFORMATION

If you have questions or concerns about this Policy, our privacy practices, or a California privacy request, contact us at:

Global Advisers, LLC
1650 Market Street, Suite 3600
Philadelphia, Pennsylvania 19103

Telephone: 800-832-8514
Email: corporate@globaladvisers.com