Privacy Policy

Regulation S-P Privacy Policy & Procedures

Firm: P.R. Curtman Investments LLC
Jurisdictions: Florida (primary), Missouri
Effective Date: 01/15/2026
Approved By: Chief Compliance Officer (CCO)

PR Curtman Investments LLC is committed to protecting your privacy. This Privacy Policy describes how we collect, use, share, and protect personal information when you subscribe to or receive our SMS (text) and email newsletters via Mailchimp.

1. Purpose and Scope

This Privacy Policy and Procedures Manual is adopted pursuant to Regulation S-P under Section 504 of the Gramm-Leach-Bliley Act (“GLBA”). The purpose of this policy is to protect the confidentiality and security of nonpublic personal information (“NPI”) of clients and prospective clients, to limit disclosure of such information, and to establish safeguards consistent with the Firm’s size, structure, and business practices.

This policy applies to all officers, employees, administrative staff, independent contractors, and third-party service providers of P.R. Curtman Investments LLC (“the Firm”) who have access to client information.

2. Definitions

Nonpublic Personal Information (NPI): Personally identifiable financial information provided by a client or obtained by the Firm in connection with providing advisory services, excluding publicly available information.

Customer: A natural person who has an ongoing advisory relationship with the Firm.

Service Providers: Third parties engaged to perform functions necessary to provide advisory services.

3. Categories of Information Collected

The Firm collects and maintains NPI necessary to provide investment advisory services, including but not limited to:

Name, address, telephone number, and email address
Social Security number and date of birth
Custodial account numbers and related account information
Financial statements and tax returns
Risk tolerance questionnaires and Nitrogen reports
Estate planning documents

The Firm does not collect health information or insurance underwriting data.

4. Use and Disclosure of Client Information

4.1 Permitted Disclosures

The Firm may disclose NPI only as necessary to provide advisory services or as permitted by law, including disclosure to:

Qualified custodians (e.g., Charles Schwab)
Portfolio management and reporting platforms
Financial planning software
Risk tolerance and analytics tools (e.g., Nitrogen)

All disclosures are limited to information reasonably necessary to perform the applicable service.

4.2 Prohibited Disclosures

The Firm does not:

Sell, trade, or rent client information
Share client information for marketing purposes
Share client information with insurance agents, marketing vendors, or affiliated entities

5. Information Security and Safeguards

5.1 Physical and Technical Safeguards

The Firm maintains reasonable safeguards designed to protect NPI, including:

Password-protected computers and systems
Two-factor authentication for all systems where available, including CRM, custodian portals, cloud storage, and email
Restricted access to systems based on job function
Secure cloud-based storage platforms (Advyzon and Dropbox)
No paper file storage of client records

Client information may be stored on local computer hard drives. Access to such devices is restricted to authorized personnel only.

5.2 Administrative Safeguards

Access to NPI is limited to the CCO, administrative staff, and authorized personnel based on job responsibilities
Background checks are conducted on personnel with access to NPI
Independent contractors with access to NPI are required to sign confidentiality and non-disclosure agreements
Third-party service providers are selected based on their ability to maintain appropriate confidentiality safeguards

The Firm does not represent that all data is encrypted. Where encryption is provided by third-party platforms, the Firm relies on those safeguards.

6. Privacy Notice Delivery

6.1 Initial Delivery

Clients receive the Firm’s Privacy Notice at the inception of the advisory relationship via one or more of the following methods:

Paper copy at onboarding
Electronic delivery through client portal
Website posting

6.2 Acknowledgment and Consent

The Firm does not require clients to provide written acknowledgment of receipt of the Privacy Notice or separate written consent for electronic delivery of communications. Delivery of the Privacy Notice is deemed effective when provided through the Firm’s standard onboarding process or made continuously available via the Firm’s website or client portal, consistent with Regulation S-P requirements.

6.3 Recordkeeping

The Firm maintains a current version of its Privacy Notice and records reflecting when the notice was adopted, amended, and made available to clients. The Firm does not maintain individual client acknowledgments or read receipts, as Regulation S-P does not require proof of receipt. The Firm’s procedures are designed to ensure that the Privacy Notice is provided or made available to all clients at the inception of the advisory relationship.

7. Incident Response and Breach Procedures

7.1 Identification and Investigation

In the event of a suspected or actual data breach, loss of device, or unauthorized access:

The CCO will promptly investigate the incident
Access will be restricted as necessary to prevent further exposure

7.2 Notification

If notification is required under federal or Florida law:

Clients will be notified without unreasonable delay
Regulators will be notified as required

7.3 Documentation

All incidents and remedial actions will be documented and retained as part of the Firm’s compliance records.

8. Florida and Missouri Compliance

The Firm maintains a written information security program consistent with Florida and Missouri requirements, including:

Reasonable administrative, technical, and physical safeguards
Breach response and notification procedures

This program is designed to be appropriate to the Firm’s size, complexity, and risk profile.

9. Oversight and Review

The CCO is responsible for administering and enforcing this policy
This policy is reviewed at least annually and updated as necessary
Employees and contractors are required to comply with this policy as a condition of access to NPI

Last Updated: 01/15/2026