PRIVACY POLICY NOTICE

Last Updated: September 1st, 2026

INTRODUCTION

At Kroeger Financial Partners (“KFP,” “we,” “us,” or “our”), we respect your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you engage with our investment advisory services.

KFP is an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940. As an SEC-registered adviser, we are subject to federal regulations, including SEC Regulation S-P (implementing the Gramm-Leach-Bliley Act, “GLBA”). We also comply with California’s Financial Information Privacy Act with respect to our California clients. The California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) apply to us only in limited respects, as described below.

DEFINITIONS

  • Consumer – an individual who has not entered into an investment advisory relationship with our firm but has disclosed nonpublic personal information to us.
  • Client – an individual who has entered into an investment advisory relationship with our firm or that individual’s designated representative.
  • Personal Information – information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or client. This includes, but is not limited to, name, address, age, Social Security number, assets, income, net worth, account balances, account numbers, beneficiary information, investment history, and other financial information.
  • Sensitive Customer Information – any component of customer information that, if compromised, could create a reasonably likely risk of substantial harm or inconvenience to the customer (for example, Social Security number, account number in combination with a password, or biometric data used for authentication). This term governs when the breach notification obligations described below are triggered.

CATEGORIES OF INFORMATION WE COLLECT

We collect personal information about you through various channels, including:

  • Account applications, forms, and other information you provide to us in person, by phone, or electronically
  • Your transactions with us, our affiliates, or others
  • Interactions with our website and digital platforms
  • Third-party verification services and consumer reporting agencies
  • Public sources and records

The categories of personal information we collect may include:

  • Identifiers (name, address, email, phone number, Social Security number, etc.)
  • Financial Information (income, assets, net worth, investment objectives, risk tolerance)
  • Protected Classification Characteristics (age, citizenship, marital status)
  • Commercial Information (products or services purchased, account balances, payment history)
  • Professional/Employment Information (current and past employment, business affiliations)
  • Health Information (as shared by you for financial planning purposes)

We may also collect the above categories of personal information from you about related parties, including spouses, children, parents, ex-spouses and others who are relevant to your financial plan.

HOW WE USE YOUR INFORMATION

We use your personal information for the following business purposes:

  • To provide you with investment advisory services
  • To process transactions and maintain your account(s)
  • To create and maintain your client profile
  • To verify your identity and prevent fraud
  • To respond to your requests and communications
  • To provide you with information about other financial products and services
  • To fulfill our regulatory compliance obligations
  • To protect the security and integrity of our services
  • To improve our services and develop new offerings

INFORMATION SHARING PRACTICES

KFP has no affiliated companies. We do not share your personal information with affiliates because none exist. We may share your personal information with the following non-affiliated third parties:

  • Service Providers – Companies that perform services on our behalf, such as account administration, technology support and professional services (accounting, legal)
  • Financial Services Partners – Broker-dealers, custodians, and other financial institutions necessary to service your accounts
  • Legal and Regulatory – Government agencies, law enforcement, courts, and other parties as required by law or regulatory authorities
  • Business Transactions – Parties involved in potential business transactions, such as mergers, acquisitions, or sales of business assets (subject to confidentiality agreements)

We do not sell or share (as “share” is defined under the CPRA) your personal information.

Service provider oversight. Consistent with SEC Regulation S-P, we require service providers with access to your information to take appropriate measures to protect it, and, for service providers holding customer information on our systems, to notify us as soon as possible — and in any event within 72 hours — after they become aware that a breach in security has resulted, or is reasonably likely to have resulted, in unauthorized access to customer information.

DATA BREACH & INCIDENT NOTIFICATION

We maintain a written incident response program, as required by SEC Regulation S-P, designed to detect, respond to, and recover from incidents involving unauthorized access to or use of customer information. This program includes procedures for assessing the nature and scope of an incident, identifying the customer information involved, and taking appropriate steps to contain and remediate it.

  • When we will notify you. If we become aware that your sensitive customer information has been, or is reasonably likely to have been, accessed or used without authorization, we will notify you as soon as practicable, and in any event no later than 30 days after we become aware of the incident, unless we determine the incident is not likely to result in substantial harm or inconvenience to you.
  • What the notice will include. Our notice to you will describe, to the extent known, what happened, the type of sensitive customer information involved, what we are doing to investigate and respond, and steps you can take to protect yourself, along with contact information for follow-up questions.
  • State law. Depending on your state of residence, you may have additional breach notification rights. California residents, for example, are separately entitled to notice under California Civil Code § 1798.82, which requires notification in the most expedient time possible and without unreasonable delay. Where state and federal timing requirements differ, we will follow whichever requires the more prompt notice.

YOUR PRIVACY RIGHTS

Federal Rights (All Clients)

Under federal law, you have the right to:

  • Receive this privacy notice annually
  • Limit certain sharing of your information with non-affiliated third parties for marketing purposes
  • Request information about our privacy practices

California Resident Rights

Two California-specific protections apply to the personal information we handle, in addition to the federal rights above:

  • Opt-in consent for certain sharing. Under the California Financial Information Privacy Act (Cal. Fin. Code Div. 1.4, commencing with §4050), we will not share your nonpublic personal information with nonaffiliated third parties beyond GLBA’s standard exceptions (service providers, legal/regulatory disclosures, fraud prevention, and similar operational uses) unless you first affirmatively opt in. We do not currently share information beyond those exceptions.
  • Breach notification. California residents are entitled to notice of certain security breaches under Cal. Civ. Code §1798.82, as described above under “Data Breach & Incident Notification.”

The CCPA/CPRA’s broader consumer rights — to know, delete, correct, opt out of sale or sharing, and limit use of sensitive personal information — generally do not apply to personal information we collect, process, or disclose in connection with providing advisory services, because that information is covered by GLBA and the California Financial Information Privacy Act (Cal. Civ. Code §1798.145(e)). This exemption applies to that category of information, not to our firm as a whole — information we may collect outside that context, such as general website analytics from visitors who never become clients, is not covered by it.

HOW TO EXERCISE YOUR RIGHTS

To exercise your privacy rights:

Call us at:
(530) 478-9734

Email us at:
[email protected]

Write to us at:
Kroeger Financial Partners
12430 Nevada City Hwy
Grass Valley, CA 95945

For verification purposes, we may require additional information to confirm your identity before responding to your request. We will respond to verified requests within 45 days, unless we require an extension.

OPT-OUT AND OPT-IN RIGHTS

Federal Opt-Out Rights:
You can limit our sharing with our affiliates for marketing purposes and our sharing with non-affiliates for marketing purposes.

California Opt-Out Rights:
California residents can opt-out of information sharing as described in the California Resident Rights section.

To exercise either right, please contact us using the information provided above. Your election will remain in effect until you revoke it in writing. Please note that we will continue to share information as permitted or required by law regardless of any opt-out or opt-in election.

DATA SECURITY

SEC Regulation S-P’s Safeguards Rule (17 C.F.R. § 248.30(a)) requires us to adopt written policies and procedures reasonably designed to (1) ensure the security and confidentiality of customer records and information, (2) protect against anticipated threats or hazards to their security or integrity, and (3) protect against unauthorized access to or use of customer information that could result in substantial harm or inconvenience to any customer. We maintain administrative, technical, and physical safeguards designed to meet this standard, including:

Our Information Security Program

  • Encryption of sensitive data, both in transit and at rest
  • Multi-factor authentication and role-based access controls that limit access to personal information to those who need it to perform their job functions
  • Secure facilities and systems, including firewalls and endpoint security monitoring
  • Periodic risk assessments to identify and address internal and external threats to customer information
  • Ongoing employee training on privacy and security practices, including how to recognize and respond to phishing and other social engineering attempts
  • Periodic testing and monitoring of the effectiveness of our safeguards
  • A written incident response program, as described above under “Data Breach & Incident Notification”

Service Provider Oversight

Before engaging a service provider with access to your personal information, we conduct due diligence on that provider’s data security practices. Our contracts with service providers require them to implement safeguards appropriate to the sensitivity of the information they access and, as described above under “Information Sharing Practices,” to notify us as soon as possible — and in any event within 72 hours — after becoming aware of a breach affecting customer information on our systems. We monitor our service providers’ compliance with these requirements on an ongoing basis.

Disposal of Customer Information

When personal information is no longer needed for the purposes described in this Privacy Policy, or as required by our recordkeeping obligations, we take reasonable measures to dispose of it in a manner that protects against unauthorized access to or use of the information, consistent with SEC Regulation S-P’s disposal rule.

Despite these measures, no security system is impenetrable. In the event of a breach involving your personal information, we will notify you in accordance with the Data Breach & Incident Notification section above and applicable law.

DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Factors we consider in determining retention periods include:

  • Legal and regulatory requirements
  • Contractual obligations
  • Business operational needs
  • The sensitivity of the information

ONLINE PRIVACY PRACTICES

Cookies and Tracking Technologies

Our website may use cookies and similar tracking technologies to enhance your experience and collect information about how you use our site. This may include:

  • Authentication cookies
  • Analytics cookies that help us understand how visitors interact with our website
  • Functional cookies that remember your preferences

Do Not Track / Global Privacy Control

We currently do not respond to browser “Do Not Track” signals. Because we do not sell or share personal information, we do not currently process opt-out preference signals such as Global Privacy Control as sale/share opt-outs.

CHANGES TO OUR PRIVACY POLICY

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the updated policy on our website, sending you an email notification, or including a notification with your account statement.

CONTACT INFORMATION

If you have any questions or concerns about this Privacy Policy, please contact us:
Kroeger Financial Partners
12430 Nevada City Hwy
Grass Valley, CA 95945
Phone: (530) 478-9734
Email: [email protected]

IMPORTANT INFORMATION

  • We deliver this Privacy Notice to you at the start of our advisory relationship and annually thereafter, or at any time a material change is made.
  • This Privacy Notice replaces all previous notices of our consumer privacy policy and may be amended at any time.
  • If you have a joint account, we are providing this notice to the primary account holder. Please share this information with all parties to your account.