PRIVACY POLICY NOTICE

Last Updated: June 20, 2025

INTRODUCTION

At Kroeger Financial Partners (“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.

As a registered investment advisor based in California, we are subject to federal regulations, including SEC Regulation S-P (implementing the Gramm-Leach-Bliley Act), as well as state regulations, including the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

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.

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

Sharing with Non-Affiliates
We may share your personal information with non-affiliated third parties in the following circumstances:

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 rent your personal information to third parties.

YOUR PRIVACY RIGHTS

Federal Rights (All Clients)

Under federal law, you have the right to:

Receive this privacy notice annually
Limit some sharing of your information
Request information about our privacy practices

California Resident Rights

If you are a California resident, you have additional rights under the CCPA/CPRA:

Right to Know – You can request information about the personal information we have collected about you, including specific pieces of information, categories collected, sources, business purpose, and categories of third parties with whom we’ve shared your information.
Right to Delete – You can request deletion of personal information we have collected from you, subject to certain exceptions.
Right to Correct – You can request correction of inaccurate personal information.
Right to Opt-Out – You can opt-out of the sale or sharing of your personal information (although we do not sell personal information).
Right to Limit Use of Sensitive Information – You can request limitations on our use of sensitive personal information.
Right to Non-Discrimination – We will not discriminate against you for exercising any of these rights.

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.

OPTING OUT OF INFORMATION SHARING

If you wish to limit the sharing of your nonpublic personal information:

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 opt out, please contact us using the information provided above. Your opt-out request will remain in effect until you revoke it in writing. Please note that even if you opt out, we will continue to share information as permitted or required by law.

DATA SECURITY

We maintain physical, electronic, and procedural safeguards designed to protect your personal information.
These include:

Encryption of sensitive data
Secure facilities and systems
Access controls and authentication procedures
Employee training on privacy and security practices
Vendor risk assessment and management

Despite these measures, no security system is impenetrable. In the event of a data breach involving your personal information, we will notify you in accordance with applicable laws.

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 Signals

We currently do not respond to “Do Not Track” signals from web browsers.

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 are required by law to deliver this Privacy Notice to you annually, in writing.

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.