Privacy Policy

Gianni Morgan Financial Advisory ("GMFA," "we," "us") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit giannimorgan.com (the "Site") or communicate with us electronically.

1. Scope

This Policy applies to Site visitors, newsletter subscribers, and prospective clients. Clients receiving investment advisory services are also subject to privacy notices delivered under Regulation S-P and Form ADV, which may contain additional requirements.

2. Information We Collect

Information You Provide

• Contact details (name, email) submitted through forms
• Message content and service interests
• Newsletter subscription preferences and consent records
• Unsubscribe requests

Information Collected Automatically

• Device type, browser, operating system
• IP address and approximate geographic region
• Pages viewed, referral URLs, and session duration
• Cookies and similar technologies (see Section 8)

Client Information

When you become a client, we may collect financial account data, identification documents, tax information, risk profile responses, and correspondence necessary to provide advisory services. That data is governed by advisory agreements and regulatory obligations in addition to this Policy.

3. How We Use Information

• Respond to inquiries and schedule consultations
• Send newsletters and educational content with consent
• Improve Site performance and user experience
• Maintain security and prevent fraud
• Comply with legal and regulatory obligations
• Provide advisory services to clients

4. Legal Bases (EEA/UK Visitors)

Where GDPR applies, we process data based on consent (marketing emails), legitimate interests (Site security and analytics), and contractual necessity (client services).

5. Sharing of Information

We do not sell personal information. We may share data with:

• Service providers (hosting, email delivery, analytics) under confidentiality agreements
• Professional advisors (legal, compliance) when necessary
• Regulatory authorities when required by law
• Custodians and brokers at your direction for account administration

6. Retention

Marketing contact data is retained until you unsubscribe or request deletion, subject to backup retention limits. Client records are retained as required by securities regulations—often six years or longer. Form submissions may be stored up to twenty-four months for quality assurance unless a client relationship begins.

7. Security

We implement administrative, technical, and physical safeguards appropriate to the sensitivity of data processed. No transmission over the Internet is completely secure; you provide information at your own risk, though we work to protect it using industry practices.

8. Cookies and Tracking

Cookies help remember preferences and analyze traffic. You may disable cookies in browser settings; some features may not function optimally. We may use aggregated analytics that do not identify individuals personally.

9. Your Rights

Depending on your location, you may have rights to access, correct, delete, or restrict processing of personal information, and to opt out of certain sharing. California residents may have rights under CCPA/CPRA including knowing categories collected and requesting deletion. To exercise rights, email hello@giannimorgan.com with sufficient detail to verify your identity. We respond within applicable statutory timelines.

10. Children's Privacy

The Site is not directed to children under 13. We do not knowingly collect information from children. Contact us to delete inadvertent submissions.

11. Marketing Communications

We send marketing emails only with consent. Each email includes unsubscribe instructions. You may also use our Unsubscribe page. Transactional messages related to existing client relationships may still be sent as permitted by law.

12. International Users

Data may be processed in the United States. By using the Site, you consent to transfer and processing in jurisdictions that may have different privacy protections than your home country.

13. Do Not Track

The Site does not currently respond to Do Not Track browser signals in a uniform manner.

14. Changes to This Policy

We may update this Policy periodically. The "Last updated" date reflects revisions. Material changes will be posted prominently on the Site.

15. Data Breach Notification

In the unlikely event of a data breach affecting personal information, we will investigate promptly, mitigate harm, and notify affected individuals and regulators as required by applicable U.S. state breach notification laws. Notifications may be delivered via email or prominent Site notice depending on severity and legal requirements.

16. Nevada and Virginia Residents

Nevada residents may submit requests to verify whether we have sold covered information (we do not sell personal data as defined under Nevada law). Virginia residents may exercise consumer data protection rights similar to CCPA, including access, correction, deletion, and opt-out of targeted advertising where applicable. Submit requests to hello@giannimorgan.com with "Privacy Request" in the subject line.

17. Testimonials and Case Studies

Client stories, testimonials, and case studies on the Site may represent composite or illustrative scenarios unless explicitly identified as a specific client endorsement with written consent. Identifying details are altered to protect privacy. Results described are not guarantees of future performance.

18. Accessibility of Privacy Requests

We will not discriminate against individuals who exercise privacy rights. Authorized agents may submit requests on your behalf with documentation of authority. We may deny requests that are manifestly unfounded, excessive, or cannot be verified.

19. Contact

Privacy inquiries: hello@giannimorgan.com