What we read, and who else can.

1. Who we are

Tranche Wealth, Inc. (“Tranche”, “we”, “us”) is a registered investment adviser that provides financial planning and portfolio management to households in the United States. This policy covers this website and the Tranche service.

This text is a sample written for a fictional company. It is not a statement about any real firm.

2. The information we collect

Information you give us. Your name, email address, phone number, date of birth, address, employment, income, tax filing status, goals and the answers you give in your planning questionnaire.

Information about your accounts. Balances, holdings, tax lots, cost basis, transactions and statements from the accounts you link or ask us to manage, received from your custodian or through a data aggregator you authorize.

Information from your use of the site and app. Pages viewed, device and browser type, approximate location derived from your IP address and the time of each sign-in, collected through cookies and similar tools described in our Cookie Policy.

3. How we use it

To give you advice. Each morning our software reads your holdings, drafts the moves it believes your plan calls for and places them in front of your advisor, who approves, edits or rejects each one. The software never trades without that signature.

To run your accounts. To place approved trades with your custodian, bill our fee, send statements and keep the records the Investment Advisers Act of 1940 requires.

To keep you and the service safe. To verify your identity, detect unusual sign-ins and prevent fraud.

To improve the service. To measure how the site and app are used. We do not use your account data to train models that are offered to anyone outside Tranche.

4. What we share, and with whom

We do not sell your personal information, and we do not share it with third parties for their own marketing.

We share information only as needed to run the service: with your custodian to hold assets and execute trades, with data aggregators you authorize, with providers that host our systems, send email or verify identity, and with your accountant or attorney when you ask us to. Each provider is bound by a written contract to use the data only for the work we give it.

We may also disclose information to regulators, auditors or law enforcement when the law requires it.

5. How long we keep it

Client records, including advice given, trades placed and the advisor who signed each move, are kept for at least five years after the end of the fiscal year in which the record was last updated, as required for registered advisers.

Website visitor data is kept for up to 13 months. Questionnaires started but never submitted are deleted after 90 days.

6. How we protect it

Data is encrypted in transit and at rest. Access by our staff is limited by role, logged, and reviewed each quarter. Sign-in to your account requires a second factor.

No system is perfectly secure. If we learn of a breach that affects your information, we will tell you and the relevant authorities within the time the law sets.

7. Your choices and rights

You can see, correct or download the information we hold about you from your account settings, or by asking your advisor.

Depending on the state you live in, you may also have the right to ask us to delete information, to limit its use or to know which categories we have shared. Some records cannot be deleted while the law requires us to keep them; we will tell you which ones and for how long.

We will not treat you differently for exercising any of these rights.

8. Children

The service is meant for adults. We do not knowingly collect information from anyone under 18, except as a beneficiary or custodial account owner named by an adult client.

9. Changes and contact

We will post any change to this policy on this page with a new update date, and tell clients by email at least 30 days before a material change takes effect.

Questions about this policy can be sent through the form on our Contact page.