Privacy Policy

Protection of Your Personal Financial Information
by Sanctuary Advisors, LLC

Who We Are

Sanctuary Securities, Inc. is a broker-dealer and a member of the Financial Industry Regulatory
Authority (FINRA) and the Securities Investor Protection Corporation (SIPC). Sanctuary
Advisors, LLC is an SEC Registered Investment Adviser. Our registered representatives and
financial advisors provide financial products and services to the general public.

Financial companies choose how they share your personal information. Federal law gives
consumers the right to limit some, but not all, information sharing. Federal law also requires
us to describe how we collect information about you, under what circumstances we may
disclose the information to others, and how we safeguard your information in our possession.

Please read this notice carefully to understand our privacy policies.

Why We Collect Information

We collect and use information about you in order to provide you with our financial products
and services. For example, we use your information to determine the appropriateness of our
investment recommendations and to process transactions for your account.

What Information We Collect

The information we collect may include personal financial information such as your name,
address, social security number, assets, income, net worth, investment experience, risk
tolerance, investment objective, beneficiary designations, and other information derived from
your account application.

How We Collect Information

We obtain most information directly from you when you establish an account or purchase
financial products or services from us. For example, we may collect your personal information
directly from you when you seek financial advice about your investments, direct us to buy or
sell securities, provide employment information, or provide us with your government-issued
ID. We may also obtain information about you from our Financial Advisors, and from third
parties such as retirement plan sponsors or third-party administrators, mutual fund
companies, insurance companies, your former broker-dealer, or adviser, as well as their
registered representatives or advisors, clearing firms, or others who have provided you with
financial products or services

Information We Disclose

We may disclose information about you, as described above, to our staff, affiliates,
representatives, their affiliated businesses, non-affiliated third parties who provide you with
financial products and services, and our service providers, such as a mailing company. These
non-affiliated third parties may include retirement plan sponsors or third-party
administrators, mutual fund companies, insurance companies and agencies, other brokerdealers, and clearing firms. Our Privacy Policy is the same for current, as well as former clients.
Also, if you close your account, in the process of transferring your investments, we may share
your information with the new broker-dealer or custodian that you or your Financial Advisor
selects. We may disclose information such as your name, address, social security number, date
of birth, transactional information, or other financial information, when necessary for us to
provide you with financial products and services, or report on your account, or where
disclosure is prescribed by law. For example, we report your tax-related information to federal
and state governments, and we may disclose information during the course of an audit, or to
law enforcement or regulatory agencies. We do not disclose your information to non-affiliated
companies who intend to market their products to you. For example, we will not sell clients’
names and addresses to a catalog or marketing company.

“Opting out” of Third-Party Disclosures

Financial companies choose how they share your personal information. Federal law gives
consumers the right to limit some, but not all information sharing. Federal law also
requires us to tell you how we collect, share, and protect your personal information.

Federal law gives you the right to limit only:

  • Sharing for affiliates’ everyday business purposes – information about your creditworthiness
  • Affiliates from using your information to market to you
  • Sharing for non-affiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.
Sanctuary may utilize common information systems or databases to which employees of our
affiliates may have access that could contain your information. However, such information
will not be disclosed by a Sanctuary affiliate, except as permitted by law.

How We Protect Personal Information

To protect your personal information from unauthorized access and use, we use commercially
reasonable technical and physical security measures that comply with applicable law. When
we share information with third parties, we hold parties to commercially reasonable standards
of privacy protection. We have policies designed to ensure only those persons who need your
information to perform their job have access to it. In addition, we maintain physical, electronic,
and procedural security measures that comply with applicable regulations to protect your
information. We train our employees in the proper handling of personal information.

Other Applicable Laws

The practices described are in accordance with Federal Law. We also follow privacy
requirements under applicable state law. If a state’s privacy laws are more restrictive than those
stated in this policy, we comply with those laws.

Some state laws grant additional privacy rights to their residents. If you live in an “opt-in” state,
where we are required to obtain your affirmative consent to share your non-public personal
information with non-affiliated third parties who do not currently assist us in servicing your
account or conducting our business, your financial professional is required to obtain your
consent before they can take your information with them should they leave our firm.

California Residents: For California residents, we will not share your personal
information with non-affiliated third parties, except as required or permitted by law. In
addition, for California residents, you are afforded certain rights regarding the non-public
personal information that we collect from you, including the right to know what personal
information we have collected from you, what it is being used for, whether it is being
disclosed or sold to non-affiliated third parties, to whomit is being disclosed or sold, and the
right to request that we delete certain personal information that we have collected from you.
Please see pages 2 and 3 of this notice for more information.

Nevada Resident: We are providing you this notice, pursuant to Nevada law. If you prefer
not to receive marketing calls from us, you may be placed on our Internal Do Not Call List by
contacting your Financial Advisor.

Vermont Residents: Under Vermont law, we will not share information we collect about
Vermont residents with companies outside of Sanctuary, unless the law allows. For
example, we may share information with your consent, to service your accounts or under
distribution agreements with other financial institutions with which we have joint
distribution agreements. We will not share information about your creditworthiness
outside of Sanctuary except with your consent, but we may share information about our
transactions or experiences with you in order to service your account with third parties (for
example your Custodian) without your consent.

For Insurance Clients in AZ, CA, CT, GA, IL, ME, MA, MN, MT, NV, NJ, NC, OH, OR, and VA.
“Personal information” means any individually identifiable information gathered in
connection with an insurance transaction. We collect personal information about you from
applications or other forms you complete, your business dealings with us and other companies,
and consumer reporting agencies. We disclose your information in the following
circumstances: as described on page 1 of this Privacy Notice; with your consent; to third parties
where necessary to determine your eligibility for insurance benefits, process claims, detect fraud
or non-disclosure; to insurance regulatory authorities; to law enforcement or other governmental
authorities to protect our interests and to prevent fraud; to our service providers who process and
maintain your account and coverages; and as otherwise permitted by law; The law allows us to
share your financial information with our affiliates to market products or services to you. You
cannot prevent these disclosures, except as stated in this Privacy Notice. We protect your non-public personal information. The only employees who have access to that information are those
who must have it to provide products or services to you. You have the right to access, correct,
amend, or delete personal information that we have recorded about you. In the event of an adverse
underwriting decision, you have the right to submit a written request for the reason(s) for the
adverse decision. To exercise these rights, please submit a written request to us at
[email protected].

Questions

If you have questions about our privacy policy, you may contact your Financial Advisor, or you may contact us at:

  • Sanctuary Wealth
  • Attention: Legal Department
  • 3815 River Crossing Pkwy, Suite 200
  • Indianapolis, IN 46240

You may also call us at (317) 975-7729 or contact us electronically at [email protected].