Wealth Enhancement Mobile App – Privacy Policy

This Privacy Policy explains how Wealth Enhancement Group (“WEG”) collects, uses, stores, shares, and protects Personal Information through the Wealth Enhancement Mobile Application (the “App”).

This Policy applies to:

• Clients accessing their financial information
• Advisors using the App to support clients
• WEG employees with authorized access
• Any Personal Information processed through the App, Salesforce, MuleSoft, AWS, or related systems

WEG may collect the following categories of information:

A. Identifiers

• Name, email, phone number
• Client or advisor ID
• Authentication credentials (tokenized only)

B. Financial Information

• Account balances
• Holdings and transactions
• Aggregated held-away accounts
• Net worth data
• Historical performance reports

C. Document Uploads

• PDFs, statements, tax forms, and other documents submitted by clients or advisors

D. Device and Usage Data

• IP address
• Device type and operating system
• App activity logs
• Access timestamps
• Crash reports and diagnostic data

E. Advisor–Client Relationship Data

• Team assignments
• Primary/secondary advisor mappings
• Notes or metadata stored in Salesforce

F. Sensitive Personal Information (as defined under CPRA)

May include:

• Financial account numbers (tokenized or masked)
• Identity verification data
• Document images that contain sensitive information

WEG does not collect biometric identifiers through the App.

Information is collected through:

• Direct user entry (e.g., document uploads, profile updates)
• Advisor interactions
• Automated system integration and synchronization via:
• Salesforce
• AWS services
• MuleSoft APIs
• eMoney , Orion, and custodial feeds
• Necessary compliance and security logging systems

WEG uses Personal Information for:

A. Advisory and Client Experience

• Displaying account data
• Supporting financial planning interactions
• Allowing secure messaging and document sharing
• Providing insights or dashboards based on account data

B. Security and Authentication

• Identity validation
• Token-based authentication via Auth0
• Monitoring for suspicious activity

C. Compliance and Legal Requirements

• SEC and FINRA obligations
• GLBA financial privacy requirements
• Retention rules and supervisory duties

D. Operational Purposes

• Troubleshooting and improving app performance
• Generating usage analytics
• Maintaining system integrity

WEG does not use Personal Information for advertising or cross-context behavioral profiling.

WEG may share Personal Information only with:

A. Authorized Advisors

To support advisory services.

B. Service Providers

Including:

• AWS
• MuleSoft
• Auth0
• Salesforce
• Security monitoring tools

All Service Providers are contractually bound to safeguard Personal Information per GLBA and CCPA/CPRA.

C. Regulators

Disclosure may be required to:

• SEC
• FINRA
• State regulators
• Auditors

D. Legal Requirements

When required by subpoena, court order, or regulatory inquiry.

WEG does not sell Personal Information.

WEG uses enterprise security controls, including:

• AES-256 encryption of stored data
• TLS 1.2+ encryption for data in transit
• Role-based access controls for advisors and staff
• AWS GuardDuty , CloudTrail, and Security Hub
• Mobile device security requirements
• Continuous monitoring and vulnerability scanning

User credentials are never stored in plaintext.

Personal Information is retained:

• For at least seven (7) years after client relationship termination
• Longer where required for regulatory, audit, or legal purposes
• In encrypted AWS storage, transitioning to Glacier Deep Archive after inactivity

Users may not request deletion of records that WEG must retain by law.

California residents have rights regarding Personal Information:

• Right to Know what information WEG collects
• Right to Access specific pieces of data
• Right to Delete (subject to regulatory restrictions)
• Right to Correct inaccurate information
• Right to Limit Use of sensitive personal information
• Right to Non-Discrimination for exercising these rights

Submit requests to: privacy@wealthenhancement.com

WEG will verify identity before fulfilling requests.

The App is not intended for individuals under 18. WEG does not knowingly collect data from minors.

Users in certain states may have additional rights under:

• California CPRA
• Colorado Privacy Act
• Virginia Consumer Data Protection Act
• Connecticut Data Privacy Act
• Utah Consumer Privacy Act

WEG will honor these rights where required.

In the event of a security incident involving Personal Information:

• WEG will notify affected users in accordance with applicable state laws.
• Notifications may be provided electronically, by phone, or in writing.
• WEG will also notify regulators where legally required.

WEG may revise this Policy periodically. 

Updates will be reflected in the App or on WEG’s website with an updated “Last Updated” date.