Privacy Policy Notice

From You Directly: Name, address, date of birth, government-issued identification, financial statements, tax information, account numbers, and investment objectives provided during onboarding or at any point in our advisory relationship.

From Account Transactions: Account balances, transaction history, portfolio valuations, and related financial data generated through your accounts at Charles Schwab & Co., Inc.

From Third Parties: Credit reports, identity-verification services, and information from other financial institutions with your authorization, including account data obtained through account-aggregation services (e.g., Plaid) that you connect.

We use nonpublic personal information to provide investment advisory and financial-planning services, communicate with you regarding your account, comply with legal and regulatory obligations, prevent fraud and unauthorized access, and improve our service delivery. We do not sell your personal information to third parties for marketing purposes.

Custodian: We share necessary account information with Charles Schwab & Co., Inc. to facilitate account management and trade execution.

Service Providers: We may share information with legal counsel, accountants, and technology vendors (including our cloud-infrastructure and account-aggregation providers) who assist in delivering services, subject to confidentiality obligations.

Legal Requirements: We may disclose information as required by law, court order, or regulatory examination.

With Your Consent: We may share information with other parties as authorized by you in writing.

To the extent we share nonpublic personal information with non-affiliated third parties beyond those described above, you have the right to opt out. Contact Tiernan Patrick C. Talbot at security@valoratransitus.com or in writing at 1920 S 1st St #2201, Minneapolis, MN 55454. We will process opt-out requests within a reasonable time.

We maintain physical, electronic, and procedural safeguards to protect your nonpublic personal information. These include encryption of data at rest (AES-256) and in transit (TLS 1.2 or higher), database-level tenant isolation (row-level security) that segregates each client’s data, multi-factor authentication, least-privilege access controls, application secrets held in a dedicated managed vault, staff training, and at least annual security review. Additional authenticated encryption (AES-256-GCM) is applied to financial-account access credentials obtained through account aggregation.

We protect the nonpublic personal information of former clients in the same manner as active clients. Information is retained for the period required by applicable law and our records-retention policy, after which it is securely destroyed.

We will provide you with a revised Privacy Policy Notice when we make material changes to our information-sharing practices. This notice is delivered at the commencement of the advisory relationship and annually thereafter.