Privacy and Cookies

Last Updated: July 24, 2026

Introduction and Scope

This Privacy Policy (“Policy”) describes how Global Advisers, LLC (“Global Advisers,” “we,” “us,” or “our”) collects, uses, discloses, retains and otherwise processes Personal Information in connection with our business activities.

This Policy applies to Personal Information that Global Advisers controls or processes in connection with its business activities, including through our website, digital communications, investment advisory services, newsletters, forms and other interactions with clients, prospective clients and Website Visitors.

This Policy is intended to provide a general description of our privacy practices. Certain information, services, technologies or jurisdictions may be subject to additional privacy requirements. Where another privacy notice applies more specifically to particular information, activities or individuals, the more specific notice governs to the extent of any conflict.

Information Governed by Financial Privacy Laws

When you obtain or seek to obtain investment advisory or other financial services from Global Advisers, Personal Information collected or processed in connection with those services may be governed by federal and state financial privacy laws.

Certain information maintained in connection with an advisory relationship may be exempt from some state consumer-privacy laws because it is regulated under federal financial privacy law. Global Advisers will collect, use, disclose, retain and protect such information in accordance with the laws applicable to our investment advisory activities.

California Privacy Disclosures

Our website may collect Personal Information from California residents. The section titled California Privacy Rights and Disclosures below provides additional information concerning our online information practices and the rights that may be available to California residents.

Cookies and Similar Technologies

Our website uses cookies and similar technologies. Information about the types of cookies and technologies we use, their purposes and available choices is provided in the section titled Cookies, Analytics and Similar Technologies below and through any cookie-preference tool made available on our website.

Definitions

For purposes of this Policy:

Business Purpose means a use of Personal Information that is reasonably necessary and proportionate to operate, manage, protect or support our business activities, as permitted by applicable law.

Individual means a natural person.

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 an identified or identifiable Individual.

Personal Information does not include information that is publicly available, lawfully made available from government records, deidentified or aggregated, as defined under applicable law.

Sensitive Personal Information means a category of Personal Information subject to heightened legal protections. It may include government-issued identification numbers, account credentials, precise geolocation, health information, biometric information and other information classified as sensitive under applicable law.

Service Provider or Processor means a third party that processes Personal Information on our behalf and pursuant to our instructions for a permitted Business Purpose.

Third Party means a person or organization that is not Global Advisers and is not acting as our Service Provider or Processor with respect to the Personal Information at issue.

Website Visitor means an Individual who visits or interacts with our website or related digital services.

You and your refer to the Individual to whom this Policy applies.

Categories of Personal Information We Collect

The Personal Information we collect depends on the nature of your relationship and interactions with Global Advisers. We do not necessarily collect every category of information described below from every Individual.

Depending on the circumstances, we may collect:

Identifiers

This may include:

• Name;
• Postal address;
• Email address;
• Telephone number;
• Internet Protocol address;
• Online identifiers; and
• Similar identifying information.

Contact and Communication Information

This may include information you provide when communicating with us through:

• Email;
• Telephone;
• Text message;
• Website forms;
• Meeting-request forms;
• Newsletter subscription forms; and
• Other correspondence or communications.

Professional and Employment Information

This may include:

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

Financial and Advisory Information

When you seek or receive investment advisory services, we may collect information such as:

• Financial assets and liabilities;
• Investment holdings and account information;
• Income and expenses;
• Tax-related information;
• Retirement information;
• Financial goals and objectives;
• Risk tolerance;
• Investment experience;
• Estate-planning information;
• Insurance information;
• Beneficiary and household information; and
• Other information reasonably necessary to provide investment advisory or financial-planning services.

Commercial Information

This may include information about:

• Services obtained;
• Services considered;
• Areas of expressed interest;
• Client relationships; and
• Prior interactions with Global Advisers.

Internet and Network Activity

This may include:

• Website pages viewed;
• Links selected;
• Date and time of access;
• Referring website;
• Browser type;
• Device information;
• Operating-system information;
• Website interaction data;
• Cookie identifiers; and
• Similar usage information.

Geolocation Information

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.

Audio, Visual or Similar Information

Where permitted by law, this may include:

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

Inferences

We may derive limited inferences from other information concerning matters such as:

• Communication preferences;
• Service interests;
• Website interests; and
• 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;
• Driver’s-license or other government-issued identification information;
• Financial-account information;
• Account-access or authentication information;
• Tax information;
• Health or disability information relevant to financial planning;
• Information concerning dependents or beneficiaries; and
• Other sensitive information reasonably necessary to provide requested services or comply with legal requirements.

We use and disclose Sensitive Personal Information only for purposes reasonably necessary to provide services, maintain records, protect accounts and systems, comply with legal and regulatory obligations or otherwise as permitted by applicable law.

Please do not transmit Social Security numbers, account passwords or other highly sensitive information through unsecured email or general website contact forms.

Sources of Personal Information

We may collect Personal Information:

Directly From You

For example, when you:

• Contact us;
• Submit a website form;
• Subscribe to a newsletter;
• Schedule a meeting;
• Complete an advisory agreement, questionnaire or financial-planning document;
• Provide documents or account information;
• Communicate with us by telephone, email, text message or video conference; or
• Otherwise request information or services.

Automatically

We may collect information automatically when you visit or interact with our website through cookies, analytics services, server logs and similar technologies.

From Financial Institutions and Service Providers

With your authorization or as otherwise permitted by law, we may receive information from:

• Account custodians;
• Broker-dealers;
• Financial institutions;
• Portfolio-management systems;
• Financial-planning platforms;
• Compliance providers;
• Technology providers;
• Data-aggregation services; and
• Other vendors supporting the advisory relationship.

From Professional Advisers and Other Authorized Persons

We may receive information from attorneys, accountants, insurance professionals, trustees, family members, authorized representatives and other persons involved in your financial affairs where you authorize the communication or applicable law permits it.

From Publicly Available Sources

We may collect information from public records, government databases, professional websites, social-media platforms and other publicly available sources.

From Referral Sources and Business Contacts

We may receive Personal Information from referral sources, professional contacts, business partners or other persons who believe you may be interested in our services.

How We Use Personal Information

We use Personal Information only for purposes reasonably necessary and proportionate to operate our business, provide services, satisfy legal and regulatory obligations and protect our clients and firm.

We may use Personal Information to:

Communicate With You and Manage Relationships

This includes using Personal Information to:

• Respond to questions and inquiries;
• Schedule and conduct meetings;
• Provide requested information;
• Deliver advisory and financial-planning services;
• Provide administrative and service-related communications;
• Send regulatory or legally required communications;
• Maintain records of communications;
• Manage client and prospective-client relationships; and
• Address complaints, concerns or requests.

Provide Investment Advisory and Financial-Planning Services

This may include using information to:

• Evaluate your financial circumstances;
• Develop investment recommendations;
• Manage investment accounts;
• Prepare or update financial plans;
• Assess risk tolerance and investment objectives;
• Review retirement, tax, estate, insurance and cash-flow considerations;
• Coordinate with account custodians and other authorized professionals;
• Conduct account reviews;
• Monitor portfolios; and
• Satisfy contractual obligations.

Send Newsletters and Marketing Communications

Where permitted by law, we may use Personal Information to:

• Send newsletters;
• Provide market commentary;
• Distribute firm announcements;
• Inform you about services or educational materials;
• Invite you to events;
• Conduct marketing or promotional activities; and
• Measure the effectiveness of communications and outreach.

You may unsubscribe from marketing emails at any time by using the unsubscribe link included in the communication.

Unsubscribing from marketing communications will not prevent us from sending administrative, contractual, security, legal, regulatory or service-related communications.

Operate and Improve Our Website and Technology

This includes using Personal Information to:

• Operate and maintain our website;
• Provide website functionality;
• Analyze website usage;
• Diagnose technical problems;
• Improve website performance;
• Enhance user experience;
• Measure engagement;
• Maintain system integrity; and
• Develop or improve services and communications.

Protect Security and Manage Risk

We may use Personal Information to:

• Verify identity;
• Prevent unauthorized access;
• Detect and respond to fraud;
• Identify suspicious or unlawful activity;
• Investigate security incidents;
• Protect our systems, accounts and information;
• Protect the rights, property and safety of Global Advisers, our clients and others;
• Enforce agreements and policies; and
• Manage legal, operational and regulatory risk.

Conduct Business Administration and Analysis

We may use information for:

• Internal reporting;
• Business planning;
• Quality assurance;
• Recordkeeping;
• Compliance testing;
• Service evaluation;
• Vendor management;
• Internal research and analytics; and
• Improving our business operations.

Comply With Law and Legal Process

We may use Personal Information to:

• Comply with federal and state laws;
• Satisfy investment-adviser books-and-records requirements;
• Respond to regulatory examinations;
• Respond to lawful government, judicial or law-enforcement requests;
• Comply with subpoenas, court orders or legal process;
• Establish, exercise or defend legal claims;
• Conduct required due diligence;
• Prevent misuse of our services; and
• Fulfill other legal or regulatory obligations.

Text-Message Communications

Where Global Advisers offers text-message communications, mobile information collected for the purpose of sending text messages will not be sold or shared with Third Parties or affiliates for their independent marketing or promotional purposes.

Text-message opt-in information and consent will not be shared with Third Parties for marketing purposes.

We may disclose mobile information to telecommunications carriers, messaging providers and other Service Providers solely as necessary to transmit, administer, support or maintain the messaging service.

Message and data rates may apply.

You may opt out of receiving text messages by replying STOP where that functionality is available.

How We Disclose Personal Information

We may disclose Personal Information to the following categories of recipients, depending on the circumstances and subject to applicable law.

Account Custodians, Broker-Dealers and Financial Institutions

We may disclose information to financial institutions that maintain, process, execute, clear, settle or report activity involving your accounts or assets.

Service Providers and Processors

We may disclose Personal Information to vendors that provide services on our behalf, including:

• Website hosting;
• Information technology;
• Cybersecurity;
• Cloud storage;
• Client-relationship management;
• Portfolio accounting;
• Financial planning;
• Data aggregation;
• Email delivery;
• Electronic signatures;
• Document storage;
• Analytics;
• Communications;
• Compliance consulting;
• Recordkeeping;
• Legal services;
• Accounting services; and
• Other operational support.

Service Providers and Processors are authorized to use Personal Information only as necessary to provide services to us, comply with applicable law or as otherwise permitted under their agreements with Global Advisers.

Professional Advisers and Authorized Representatives

At your direction or with your authorization, we may disclose information to:

• Attorneys;
• Accountants;
• Insurance professionals;
• Trustees;
• Executors;
• Agents under powers of attorney;
• Family members;
• Beneficiaries; and
• Other professional advisers or authorized persons.

Government, Regulatory and Legal Authorities

We may disclose information to:

• Securities regulators;
• Tax authorities;
• Courts;
• Law-enforcement agencies;
• Government agencies;
• Self-regulatory organizations, where applicable; 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;
• Sale;
• Financing;
• Reorganization;
• Transfer of client relationships;
• Transfer of business assets; or
• Similar business transaction.

Any information processed in connection with such a transaction will be handled in accordance with 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.

Other Legally Permitted Disclosures

We may disclose information as otherwise permitted or required by applicable financial privacy, securities, tax, regulatory or other laws.

Sale and Sharing of Personal Information

Global Advisers does not sell Personal Information in exchange for money.

Certain website analytics, advertising, social-media or embedded-content technologies may transmit online identifiers, device information or internet activity to Third Parties.

Depending on the technology involved and the law applicable to the Individual, certain transmissions may be characterized as a “sale,” “sharing” or disclosure for targeted or cross-context behavioral advertising even when no money is exchanged.

Where applicable law provides an opt-out right, you may exercise that right through any Your Privacy Choices, Do Not Sell or Share My Personal Information or cookie-preference mechanism displayed on our website.

Global Advisers does not knowingly sell or share the Personal Information of Individuals under 16 years of age.

Cookies, Analytics and Similar Technologies

Our website may use cookies, pixels, tags, scripts, software-development tools, local storage and similar technologies.

Essential Cookies

Essential cookies support functions such as:

• Website security;
• Network management;
• Fraud prevention;
• Cookie preferences;
• Form operation; and
• Other core website functionality.

These technologies may be necessary for the website to function properly.

Analytics Cookies

Analytics technologies may help us understand:

• How visitors locate our website;
• Which pages are viewed;
• How long visitors remain on pages;
• Which links are selected;
• General geographic location;
• Device and browser characteristics; and
• Website performance.

Functional Technologies

Functional technologies may enable:

• Embedded videos;
• Interactive maps;
• Social-media content;
• Scheduling tools;
• Chat features;
• Forms; and
• Other enhanced functionality.

Advertising and Social-Media Technologies

Where enabled, advertising and social-media technologies may be used to:

• Measure communication effectiveness;
• Understand responses to advertisements;
• Build or measure audiences;
• Display content on other websites; and
• Support targeted or cross-context behavioral advertising.

Managing Cookie Preferences

You may manage nonessential cookies through the cookie-preference tool displayed on our website, where available.

You may also configure your browser to block, restrict or delete cookies. Blocking cookies may affect website operation or prevent certain features from functioning.

Do Not Track and Global Privacy Control

Some web browsers provide a “Do Not Track” signal.

Because there is not a universally accepted technical or legal standard governing ordinary Do Not Track signals, our website may not respond to traditional Do Not Track browser settings in a uniform manner.

Global Privacy Control and similar legally recognized opt-out preference signals are different from traditional Do Not Track signals.

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 treat the signal as a request to opt out of the sale or sharing of Personal Information associated with that browser or device.

Your opt-out preference may apply only to the browser, device or profile from which the signal is sent.

Third-party analytics, social-media, advertising, embedded-content and other technology providers may collect information concerning your online activities over time and across different websites or online services.

How Long We Retain 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.

Retention periods vary depending on:

• The nature and sensitivity of the information;
• The relationship involved;
• The purpose for which the information was collected;
• Legal and regulatory retention requirements;
• Contractual 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.

We may retain deidentified or aggregated information for a longer period where the information can no longer reasonably be associated with an identifiable Individual.

Your Privacy Choices

Privacy choices depend on your relationship with Global Advisers, the nature of the information and applicable law.

Marketing Emails

You may unsubscribe from marketing emails by selecting the unsubscribe link at the bottom of the message.

You may continue to receive administrative, legal, regulatory, security and service-related communications.

Text Messages

You may opt out of text messages by replying STOP where that function is available.

Cookie Choices

You may adjust cookie preferences through our website’s cookie-preference tool and through your browser settings.

Correcting Information

You may contact us to request correction of Personal Information you previously provided through the website.

We may be required to retain historical records and may not be able to alter information contained in records that must be preserved for legal, compliance or regulatory reasons.

Financial Information

Requests involving information maintained in connection with an investment advisory relationship may be subject to federal or state financial privacy laws, securities-recordkeeping requirements and other legal exemptions.

California Privacy Rights and Disclosures

This section applies to Personal Information collected from California residents through our website and other online services.

California Online Privacy Protection Act Disclosures

Under the California Online Privacy Protection Act, our online privacy practices include the following:

Categories of Personally Identifiable Information Collected

We may collect the categories of information identified in this Policy, including:

• Names;
• Postal addresses;
• Email addresses;
• Telephone numbers;
• Online identifiers;
• Internet Protocol addresses;
• Professional information;
• Communication information;
• Website-interaction information; and
• Other information voluntarily submitted through the website.

Categories of Third Parties

We may disclose online information to the categories of recipients described in this Policy, including:

• Website-hosting providers;
• Information-technology providers;
• Cybersecurity providers;
• Analytics providers;
• Email and communications providers;
• Customer-relationship-management providers;
• Professional advisers;
• Government and regulatory authorities; and
• Other parties at your direction or as permitted by law.

Reviewing or Requesting Changes to Information

You may contact us using the information in the Contact Information section to request review or correction of Personal Information you previously submitted through the website.

We may request information necessary to verify your identity before responding.

We may decline or limit a request where the information is subject to a legal or regulatory retention requirement or another applicable exception.

Changes to This Policy

The date shown at the top of this Policy indicates when it was most recently updated.

We may provide additional notice of material changes where appropriate.

Do Not Track and Third-Party Collection

Our response to Do Not Track signals and legally recognized opt-out preference signals is described in the section titled Do Not Track and Global Privacy Control.

Third parties may collect Personal Information concerning Website Visitors’ online activities over time and across different websites when third-party cookies, analytics, social-media features or embedded technologies are enabled.

California Consumer Privacy Act

Global Advisers may not meet the statutory definition of a covered “business” under the California Consumer Privacy Act and California Privacy Rights Act in every year or circumstance.

To the extent that Global Advisers is subject to the CCPA with respect to particular Personal Information, California residents may have the rights described below, subject to statutory exceptions and exemptions.

Certain Personal Information collected, processed, sold or disclosed pursuant to federal financial privacy law may be exempt from some CCPA requirements.

Right to Know and Access

You may have the right to request information concerning:

• The categories of Personal Information 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 the information was disclosed;
• The categories of Personal Information sold or shared, if any;
• The categories of Personal Information disclosed for a Business Purpose; and
• Specific pieces of Personal Information maintained about you.

Right to Delete

You may have the right to request deletion of Personal Information collected from you, subject to exceptions.

We may retain information where necessary to:

• Complete a transaction;
• Provide requested services;
• Maintain investment-advisory records;
• Detect and prevent fraud or security incidents;
• Exercise or defend legal claims;
• Comply with legal or regulatory obligations;
• Maintain records of privacy requests; or
• Use the information internally in a manner permitted by law.

Right to Correct

You may have the right to request correction of inaccurate Personal Information maintained about you.

Right to Opt Out of Sale or Sharing

You may have the right to opt out of the sale or sharing of Personal Information.

Global Advisers does not sell Personal Information in exchange for money.

Certain online advertising, analytics or social-media technologies may nevertheless constitute “sharing” under California law when information is used for cross-context behavioral advertising.

Where applicable, you may submit an opt-out request through the website’s Your Privacy Choices, Do Not Sell or Share My Personal Information or cookie-preference mechanism.

Right to Limit Use of Sensitive Personal Information

Where Global Advisers uses or discloses Sensitive Personal Information for purposes that create a right to limit under California law, you may have the right to direct us to limit that use or disclosure.

Global Advisers generally uses Sensitive Personal Information for purposes reasonably necessary to provide financial services, verify identity, secure accounts, comply with law and perform other legally permitted functions.

Right to Data Portability

You may have the right to receive certain Personal Information in a portable and, where technically feasible, readily usable format.

Right to Non-Discrimination

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

Authorized Agents

Where permitted by law, an authorized agent may submit a request on your behalf.

We may require:

• Written authorization;
• Proof of the agent’s authority;
• Direct verification of your identity; or
• Other information permitted by law.

Verification of Requests

We may take reasonable steps to verify:

• Your identity;
• Your California residency;
• The information associated with you;
• The nature of the request; and
• The authority of an authorized agent.

Information collected for verification will be used only for verification, security, fraud-prevention, legal or recordkeeping purposes.

Responding to Requests

Where the CCPA applies, we will respond within the period required by applicable law.

If additional time is reasonably necessary, we will provide notice of the extension where required.

We may deny or limit a request when an exception applies, the request cannot be verified or the information is not subject to the applicable law.

Submitting a California Privacy Request

California privacy requests may be submitted by:

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

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

How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to protect Personal Information against unauthorized access, acquisition, use, alteration and disclosure.

Our safeguards are designed to be appropriate to:

• The nature and sensitivity of the information;
• The risks associated with its processing;
• The systems and services involved; and
• Applicable legal and regulatory requirements.

Safeguards may include:

• Written policies and procedures;
• Access restrictions;
• Authentication controls;
• System and network protections;
• Secure transmission and storage methods;
• Employee training;
• Vendor oversight;
• Incident-response procedures; and
• Physical-access controls.

No method of internet transmission, electronic storage or information security is completely secure. We therefore cannot guarantee absolute security.

You should not transmit passwords, Social Security numbers, account credentials or similarly sensitive information through unsecured email or public website forms.

Third-Party Websites and Services

Our website may contain links to or integrations with websites and services that Global Advisers does not own or control.

Those services may include:

• Account custodians;
• Client portals;
• Scheduling platforms;
• Social-media platforms;
• Video providers;
• Map providers;
• News or research websites;
• Financial-information providers; and
• Other third-party services.

Information you provide directly to a Third Party is governed by that Third Party’s privacy practices and terms.

This Policy does not apply to Personal Information independently collected or controlled by a Third Party.

A link to a Third Party does not necessarily constitute an endorsement of that party’s privacy, security, content or business practices.

Children’s Privacy

Our website, services and communications are directed to adults and are not intended for children under 13.

We do not knowingly collect Personal Information online from children under 13.

If we learn that we have collected Personal Information from a child under 13 without legally valid authorization, we will take reasonable steps to delete it.

Changes to This Policy

We may update this Policy periodically to reflect changes in:

• Our information practices;
• Website technology;
• 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 before a material change becomes effective.

The revised Policy supersedes prior versions as of its effective date.

Contact Information

Questions, concerns, and privacy requests may be directed to:

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

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