Privacy Policy

Note

Four providers named that were already part of the service and were missing from this notice: Charles Schwab & Co., Inc. (the qualified custodian for accounts on Schwab Advisor Services - every other custodian was named, this one was not); Performance Technologies, Inc. d/b/a Schwab Intelligent Technologies (the firm enrolled in Schwab OpenView Gateway on this date, and under that agreement the requested account data is replicated and maintained in a database at that entity before delivery, so naming only the custodian would understate where client data rests); RightCapital, Inc. (the Client Advisory Agreement commits to delivering the written plan through it and providing client access, so planning data has always flowed there while the notice did not say so); and Monarch Money (named because the same agreement names it, with the entry stating first that Protocol Wealth transmits nothing to it - a client holds their own account and the only flow is inbound when an export is uploaded). Classified material because it names new recipients of client information, though under the companion List of Subprocessors' own test it expands no category of data shared, no geography of processing, and no class of AI service. A new Financial Planning heading was added for the two planning providers. No change to what is collected or why.