Regulation S-P Privacy Policy & Procedures
Firm: P.R. Curtman Investments LLC
Jurisdictions: Florida (primary), Missouri
Last Updated on: 10/23/2026
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.
AI-Assisted Prospect Communications
- The Firm uses third-party technology platforms to facilitate prospect communications, appointment scheduling, document management, and marketing communications. Information provided by prospective clients through these platforms may be transmitted to and stored by such service providers solely for the purpose of facilitating communication with the Firm.
- All third-party platforms are selected based on their ability to maintain appropriate security and confidentiality standards. The Firm does not authorize these platforms to use prospect information for any purpose other than facilitating communication with the Firm.
- Information collected from prospective clients prior to the establishment of an advisory relationship is subject to the same confidentiality standards as client nonpublic personal information and is never sold or shared to third parties for their own marketing purposes.
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
4.3 Website Analytics, Cookies and Advertising Measurement
When you visit www.prcurtman.com, the Firm uses cookies and similar technologies from Google (Google Analytics and Google Ads) and Meta (the Meta Pixel) to understand how visitors use the site and to measure whether our advertising works. These tools may collect information such as the pages you view, the device and browser you use, and the ad or link that brought you to the site.
If you arrive from an ad or a tracked link, the site records the ad click identifier and campaign details (for example, a Google click ID and campaign tags). If you later give us your email address through a form or the PRC AI chat assistant, those ad details are stored with your contact record in the Firm’s internal lead records so we can tell which advertising is working.
If you become a client, the Firm may report to Google Ads that the ad click led to a new client, along with an estimated value. That report contains only the ad click identifier, the date and the estimated value. It does not include your name, email address, phone number, account information or other personal financial information.
The Firm does not upload client lists or client contact information to advertising platforms and does not use them to target advertising.
You can limit or block cookies in your browser settings, manage Google ad personalization at myadcenter.google.com, and manage Meta ad preferences in your Facebook or Instagram settings. Blocking cookies will not prevent you from using the site.
4.4 PRC AI Chat Assistant
PRC AI is an AI assistant on www.prcurtman.com. It collects the information you share and offers general, educational information, not personal investment or financial advice. Please consult a financial professional before making decisions.
When you give PRC AI or one of our website forms your email address to request a free guide, you agree to receive that guide and occasional emails from P.R. Curtman Investments. You can unsubscribe anytime using the link at the bottom of any email.
Information you share with PRC AI is handled under this Privacy Policy, including the AI-Assisted Prospect Communications section above. Please do not enter account numbers, Social Security numbers, passwords or other sensitive financial details into the chat.
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
Appendix A – Client Privacy Notice
P.R. Curtman Investments LLC – Privacy Notice
We respect your privacy and are committed to protecting your personal information.
Information We Collect
We collect nonpublic personal information necessary to provide investment advisory services, including identifying and financial information.
Information We Share
We may share information only as required to service your account, such as with custodians and service providers. We do not sell or share your information for marketing purposes.
How We Protect Your Information
We maintain reasonable physical, electronic, and administrative safeguards to protect your information.
Website and Advertising
Our website uses cookies from Google and Meta to measure site traffic and advertising. If you become a client after clicking one of our ads, we may tell Google that the ad click led to a new client. We do not share your name, contact details or account information with advertising platforms.
Questions
If you have questions about this notice, please contact us at:
WWW.PRCURTMAN.COM
Last Updated: 10/23/2026
