Privacy Policy

Abbey Street, LLC (“Abbey Street”) values your business. We also value the trust that you have placed in us. We strongly believe in protecting the confidentiality and security of the information that we collect or which is provided to us. We encourage you to read this Privacy Policy (“Policy”) carefully to understand our privacy practices.
As used herein, the term “you” and “your” shall mean you, individually, and each other party on whose behalf you may use Abbey Street’s website at any time. All references to “we”, “us” or “our” shall refer to Abbey Street. The Website is operated by Abbey Street, LLC.
This Policy describes the types of information we collect from you when you contact us and when we provide services to you, or that you provide to us when you visit our website, as well as our practices for collection, use, disclosure and protection of such information.
This Policy should be read in conjunction with any applicable Website Terms of Use policy which references this Policy.

Information We Collect

Abbey Street may collect, store, use and/or disclose personal information, including information that can be used to identify you as an individual, in the course of servicing you as a client or as a user of our website. We may also gather information about browsing activities, data accessed or reviewed, or other information related to your use of our website. By using or continuing to use our website, you agree to and accept the terms of this Policy.
We collect certain information about individuals who apply for or obtain products or services from us, including information provided through forms, transactions and interactions with our firm. This information may include:
• Personal data such as name, address, email address, telephone number, date of birth, driver’s license number and social security number.
• Financial data, such as your income, assets and transaction histories.
• Credit history and investment history.
• Data about your relationship with Abbey Street, such as products or services you have purchased, investment account balances, and payment data and history.
• Data received in connection with your interactions with Abbey Street, such as when you visit our website or when you correspond with our team members.

Collecting this data permits us to provide effective client service to you based on your financial position and needs, offer relevant products and services, and comply with legal and regulatory requirements. The type of information we collect depends on whether you are a client of Abbey Street, and also varies based on the services you request or receive from us. We collect personal information, including direct or indirect identifiers, from the following sources:
• From non-affiliated third parties with which you have dealt, such as other wealth management firms or investment advisors.
• From banks, insurance providers, retirement plan administrators and other plan administrators from which you authorize us to obtain information regarding your financial accounts and strategies.
• From other outside sources, such as consumer reporting agencies, motor vehicle reporting agencies, and employers.
• Directly from clients and prospective clients, such as when you open an account with us, engage in investment transactions, enter into an advisory agreement, seek advice regarding your investments, provide information to us regarding your financial transactions or earnings, or when you otherwise inquire about or obtain services from us.
• Directly from clients and website visitors through communications with Abbey Street, such as information you provide through email, telephone correspondence or our online contact form.
• Indirectly from visitors to the Abbey Street websites, such as information relating to your use of our products and services, information about your transactions with us, our affiliates or others, or information relating to your use or interaction with our websites and forms (including IP addresses and location data).

Use of Information

We do not disclose your non-public personal information except as permitted or required by applicable law or regulation. Subject to the foregoing, we may use and disclose personal information for business purposes related to the products and services we offer, including for the purpose of assessing requests that are made for advisory and other services we offer; the administration of our services; and the processing of transactions. In particular, we may use and disclose the information we collect for one or more of the following business purposes:

• To determine your eligibility for our products and services.
• To open and service your account, including to complete transactions or account changes as directed by you.
• To contracted third parties, administrators and vendors used by Abbey Street to effect, administer, develop, support and/or provide our services to you.
• To promote and offer you a full range of products and services that may meet your needs or interests.
• To provide you with products or services that you request from us, and to communicate with you and provide information about those requests.
• To provide you with email updates, event invitations or registrations and other notices concerning our products or services, or to otherwise provide you with relevant information about our services that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any agreements entered into between you and Abbey Street, including for billing, payment and collections.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or security of Abbey Street, our clients or others, such as to verify your identity and to detect, prevent, or investigate fraud or security breaches.
• To respond to your questions or concerns.
• To comply with applicable legal and regulatory obligations.
• To protect the security or integrity of our website and our business.
• As otherwise described to you when collecting your personal information.

Abbey Street discloses personal information to third parties only as permitted by law. This primarily includes disclosures that are needed to establish your client investment accounts, provide services you request, and to process payments, transactions and verifications, as well as for customer service purposes. We may also make disclosures to other financial institutions with which we have joint marketing agreements. We do that in order to provide a better range of benefits to our members. Additionally, we may disclose personal information to comply with our legal or regulatory obligations, for audit purposes, to detect and prevent security incidents and to determine technical functionality improvements. We may also use or share aggregated information for statistical research or analysis or to optimize user experience.

This Policy does not restrict our collection, use or disclosure of any aggregated information or information that does not identify, or cannot be reasonably linked to, any individual.

Abbey Street does not provide your personal information to mailing list vendors or solicitors, or share such information with non-affiliated third parties for marketing purposes. Furthermore, Abbey Street does not sell your personal information for any purpose.

Limiting Use of Information

You may request that we delete any personal information by contacting us in writing at info@abbeystreet.com. We will ask you to verify your identity and will attempt to make any deletion request effective as soon as is commercially possible. However, we will retain information connected to your account in accordance with applicable laws. You may decline to provide certain information to Abbey Street; however, such declination may disqualify you from using our website and/or obtaining services from Abbey Street.

You may also elect to set your browser settings to opt out from online behavioral tracking by enabling “Do Not Track” or other similar functions or settings. However, please note that Abbey Street does not track clients over time and across different websites for targeted advertising, and thus may not respond to “Do Not Track” signals.

Security

Abbey Street takes reasonable steps to protect your information from loss, misuse and unauthorized access, alteration, disclosure or destruction in accordance with applicable laws and regulations. However, we cannot guarantee that any internet, email or electronic communication or operating system is ever fully secure or error-free. Please exercise diligence in deciding how you provide information to us.

Information of Minors

We do not intentionally seek to gather information from individuals under the age of eighteen (18). We do not target our website or services to minors, and would not expect them to be engaging with our website or services. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we become aware of any personal information that we have collected about minors, we will take steps to securely remove it from our systems.

Third Party Sites
Some applications and services embedded within, or linked from, our website, such as maps and social media platforms, are controlled by third-party providers. These third-parties may use cookies, alone or in conjunction with other tracking technologies, to collect information about you when you use our website or navigate away from our website. These third parties may also have privacy policies that differ from ours. For example, they may collect personal information about your online activities over time and across different websites, and other online services, and may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third-parties or their privacy practices, and this privacy notice does not apply to any third-party website or service you may access through our website. If you have any questions about a third-party provider’s privacy policies or advertising, you should review that party’s privacy policies and contact that party directly.

Complaints
Complaints can be sent to us at the address included in the “Data Accuracy” section below, or via email at info@abbeystreet.com. Some jurisdictions may also permit you to complain to a data protection authority.

How Long Data is Retained

When non-public personal information is no longer required, under our record retention procedures, it is destroyed in a secure manner. This includes information in hard copy or electronic media format.

Abbey Street also takes steps to reasonably ensure that the privacy of your information remains secure even in the event of the disposal of information that is no longer required to be maintained.  Such steps include, whenever possible and without limitation, shredding hardcopy documents and records prior to disposal and erasing and/or deleting data contained on electronic media in such a manner to ensure that the information can no longer be read or reconstructed.

Data Accuracy
Our goal is to keep the information you have on file with us accurate and up-to-date. Please contact our home office at the following address should there be an address change or other information that requires revision: Abbey Street, 775 Prairie Center Drive, Suite 400, Eden Prairie, MN 55344.
Please refer to our website: https://abbeystreet.com/privacy-policy/ for further information and complete details including information relating to privacy notices required by law in specific states in which Abbey Street conducts business. In particular, if you are a California resident, California law may provide you with additional information regarding consumer rights and our use of personal information. To learn more about California-specific privacy rights, see our CCPA Privacy Notice below.

For Website Users Outside of the United States
Our website and services are designed for use by individuals in the United States only. We do not warrant or represent that this Policy or our website’s use of your personal information complies with the laws of any other jurisdiction outside of the United States. Furthermore, to provide you with our services, we may store, process, and/or transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as those in effect where you are located. Regardless of where such information is stored, we will process your personal information in accordance with this Policy.

Changes to Privacy Party

Please review our online privacy policy and notices routinely as they may be amended periodically to reflect changes in our information practices or relevant laws. Such changes may be made at any time and without notice to you, at the sole discretion of Abbey Street. We will post a notice on our website, and we may also notify members via email, when we make substantive changes to the way we collect and/or use information. We include a date at the bottom of this privacy notice to indicate when it was last updated.
(Effective date: 11/22/2022)