Pave Investment Advisors, LLC (referred to as “Pave”) maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”). Through this policy and its underlying procedures, Pave attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.

It is the policy of Pave to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/non affiliated entities who need to know that information in order to provide products or services in furtherance of the client's engagement of Pave. In that regard, Pave may disclose the client’s information: (1) to individuals and/or entities not affiliated with Pave, including, but not limited to the client’s other professional advisors and/or certain service providers that may be recommended or engaged by Pave in furtherance of the client's engagement of Pave (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, record keeper, proxy management service provider, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. The disclosure of information contained in any document completed by the client for processing and/or transmittal by Pave to facilitate the commencement/continuation/termination of a business relationship between the client and/or between Pave and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, record keeper, insurance company, etc.), including, but not limited to, information contained in any document completed and/or executed by the client in furtherance of the client's engagement of Pave (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider.

Pave uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using the Service, you grant Pave and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy.

Pave permits only authorized employees and affiliates who have signed a copy of Pave’s Privacy Policy to have access to client information. Employees violating Pave’s Privacy Policy will be subject to Pave’s disciplinary process. Additionally, whenever Pave hires other organizations to provide services to Pave’s clients, Pave will require them to sign confidentiality agreements and/or the Privacy Policy.

Should you have any questions regarding the above, please contact Chris Ainsworth, Chief Compliance Officer, at chris@pavefinance.com.