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Palm Capital Management

Privacy Policy

Effective date: September 18, 2026

This Privacy Policy describes how Palm Capital Management (“Palm Capital,” “we,” “us,” or “our”) collects, uses, and shares information when you visit our website at palmcm.com (the “Site”), contact us through the Site, or schedule a consultation with us. It also describes the choices and rights you have, wherever in the United States you live.

Who we are

Palm Capital Management is a financial planning, retirement planning, and wealth management firm serving clients throughout the United States. Investment advisory services are offered through Dynamic Wealth Advisors (“DWA”), a registered investment adviser; Palm Capital Management is a d/b/a of DWA. You can reach us at 805.727.2700 or info@palmcm.com.

This policy covers information collected through the Site. Nonpublic personal information that we collect from you as a client or prospective client of our advisory business — for example, account numbers, income, assets, investment objectives, and transaction history — is protected under the federal Gramm-Leach-Bliley Act and SEC Regulation S-P. That information is governed by the Privacy Notice that DWA delivers when you open an account and annually thereafter, which describes the categories of nonpublic personal information we collect, the limited circumstances in which we share it (with service providers that help us administer your accounts, with your custodian, and as permitted or required by law), and how we safeguard it. We do not sell nonpublic personal information, and we do not share it with nonaffiliated third parties for their own marketing. You can request a copy of the current Privacy Notice at any time at info@palmcm.com.

Information we collect

Information you give us

You can use the Site without telling us who you are. We collect personal information only when you choose to provide it:

  • Contact form. Your name, email address, phone number, and anything you write in the comments field.
  • Referral form. Your name and email address, and the name, email address, phone number, and relationship to you of the person you are referring. Please only refer people who have agreed to be contacted by us. We use referral information solely to make the introduction you requested.
  • Consultation scheduling. If you book a consultation through the Calendly scheduler on the Site, Calendly collects your name, email address, and the time you choose, and shares it with us. Calendly’s handling of that information is described in its own privacy policy at calendly.com/privacy.
  • Email and phone. If you email or call us, we keep the correspondence and the contact details you provide.

Please do not send account numbers, Social Security numbers, passwords, or other sensitive financial information through the Site’s forms or by unencrypted email. If we need that information to open or service an account, we will collect it through secure channels.

Information collected automatically

When you visit the Site, certain information is collected automatically:

  • Analytics. We use Google Analytics 4 to understand how visitors use the Site. Google Analytics sets cookies and collects information such as the pages you view, how you arrived at the Site, the approximate location derived from your IP address, and your device and browser type. Google’s use of this information is described at policies.google.com/privacy. You can opt out of Google Analytics with the browser add-on at tools.google.com/dlpage/gaoptout.
  • Advertising. The Site uses the Meta Pixel, a tool provided by Meta Platforms, Inc. (Facebook and Instagram). The pixel sets cookies and sends Meta information about your visit, such as the pages you view, your IP address, and your browser and device type. We use this information to measure the results of our advertising and to show advertisements for our services to people who have visited the Site. Meta may also use this information for its own purposes as described at facebook.com/privacy/policy. You can control the advertisements you see from Meta at facebook.com/adpreferences, and you can opt out of the pixel on this Site as described under “Your privacy rights” below. The pixel does not receive the contents of any form you submit to us.
  • Server and security logs. Our hosting provider and Cloudflare, which delivers and protects the Site, record IP addresses, request details, and browser information to keep the Site running and to detect abuse.
  • Cookies. Cookies are small files placed on your device. The Site uses cookies for analytics and advertising measurement (described above) and for the operation of embedded services (described below). You can block or delete cookies in your browser settings; some embedded features may not work without them.

Embedded content from other services

Pages on the Site include content served by other companies. When you view a page with embedded content, that company may collect information about you, set its own cookies, and track your interaction with the content, in the same way as if you had visited its website directly. The Site currently embeds:

How we use information

We use the information described above to:

  • Respond to your inquiries and requests, including scheduling and holding consultations.
  • Make the introduction you requested through the referral form.
  • Operate, secure, and improve the Site, and understand how it is used.
  • Comply with the recordkeeping, supervisory, and other legal obligations that apply to a registered investment adviser.

We do not sell your personal information, and we do not share it with third parties for their own marketing. Information collected by the Meta Pixel for our advertising may be considered “sharing” under some U.S. state privacy laws; see “Additional rights under U.S. state privacy laws” for how to opt out. We do not use the Site to make automated decisions that have legal or similarly significant effects on you.

Who we share your data with

We share personal information only as needed to run the Site and our business:

  • Service providers that act on our instructions, such as our website host, Cloudflare, Google (analytics and maps), Meta (advertising measurement), Calendly (scheduling), and the email service that delivers form submissions to us.
  • Dynamic Wealth Advisors, through which our advisory services are offered, where a Site inquiry leads to an advisory relationship or where its supervisory obligations require it.
  • Legal and regulatory recipients, when disclosure is required by law, regulation, subpoena, or a regulator such as the Securities and Exchange Commission, or to protect the rights, property, or safety of Palm Capital, our clients, or others.
  • A successor in the event of a merger, acquisition, or sale of all or part of our business, subject to this policy.

How long we retain your data

Form submissions and correspondence are kept for as long as needed to respond to you and to meet our recordkeeping obligations as an investment adviser. Communications that relate to our advisory business are retained for at least five years from the end of the fiscal year in which they were made, as required by SEC Rule 204-2, and may be retained longer where other laws or our compliance program require it. Analytics data is retained by Google Analytics for the retention period configured in our Google Analytics account, after which it is deleted or aggregated. Server and security logs are kept for a limited period for operational and security purposes.

Where your data is stored

Our website and the services listed above store information in the United States. If you visit the Site from outside the United States, your information will be transferred to and processed in the United States, where privacy laws may differ from those of your country.

Your privacy rights

You can ask us at any time what personal information we hold about you, ask us to correct it, or ask us to delete it. To make a request, email info@palmcm.com or call 805.727.2700. We may need to verify your identity before acting on a request, and we may keep information we are legally required to retain.

Additional rights under U.S. state privacy laws

A growing number of U.S. states, including California, Colorado, Connecticut, Texas, and Virginia, have privacy laws that give their residents specific rights over personal information collected through websites like ours. We extend the rights below to all visitors, regardless of where you live. For California residents, this section also serves as our notice at collection under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”). It does not apply to nonpublic personal information collected in connection with our financial services, which is governed by the Gramm-Leach-Bliley Act and the client Privacy Notice described above. You have the following rights:

  • Right to know. You can request the categories and specific pieces of personal information we have collected about you, the sources, the purposes for collecting it, and the categories of third parties we share it with. In the preceding twelve months we have collected the categories described in “Information we collect” above: identifiers (name, email address, phone number, IP address), internet activity (analytics and advertising data), and, for referrals, the relationship between you and the person you refer.
  • Right to delete. You can request that we delete personal information we collected from you, subject to legal exceptions such as regulatory recordkeeping requirements.
  • Right to correct. You can request that we correct inaccurate personal information.
  • Right to opt out of sale or sharing. We do not sell personal information. The Meta Pixel described in “Information we collect” sends information about your visit to Meta for advertising, which some state privacy laws treat as “sharing” for cross-context behavioral advertising or as targeted advertising. To opt out, email info@palmcm.com with “Do not share” in the subject line, turn on a Global Privacy Control signal in your browser (see below), block cookies in your browser settings, or adjust your advertising settings with Meta at facebook.com/adpreferences. We do not knowingly sell or share the personal information of anyone under 16.
  • Right to non-discrimination. We will not treat you differently for exercising any of these rights.

To exercise these rights, email info@palmcm.com or call 805.727.2700. We will confirm receipt within ten business days and respond within forty-five days, extending that period once if reasonably necessary. You may designate an authorized agent to make a request on your behalf; we may ask the agent for proof of authorization and may ask you to verify your identity directly.

Global Privacy Control and Do Not Track. If your browser sends a Global Privacy Control (GPC) opt-out preference signal, the Site treats it as a request to opt out of sharing and does not load the Meta Pixel for that browser. GPC is available as a setting or extension in many browsers; see globalprivacycontrol.org. The Site does not respond to “Do Not Track” signals, for which no industry standard has been adopted.

Shine the Light. California Civil Code section 1798.83 allows California residents to request information about disclosures of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.

Client portals and links to other websites

The Site links to portals operated by other companies so that clients can view their financial plan and accounts, including MoneyGuidePro, Orion, Charles Schwab, and Fidelity. When you follow one of those links you leave the Site, and the information you provide there is collected under that company’s privacy policy, not this one. We are not responsible for the privacy practices of websites we link to.

Calls and text messages

If you give us your phone number, we may call or text you about your inquiry, your referral, or your consultation. We do not use your number for marketing text campaigns. You can ask us to stop contacting you by phone at any time by replying STOP to a text or by emailing info@palmcm.com. Message and data rates may apply.

Children

The Site is intended for adults. We do not knowingly collect personal information from anyone under 16 through the Site. If you believe a minor has provided us with personal information, please contact us and we will delete it.

Security

We use reasonable administrative, technical, and physical safeguards to protect personal information, including encrypted connections to the Site. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

Changes to this policy

We may update this policy from time to time. The effective date at the top shows when it was last revised, and the current version will always be posted on this page.

Contact us

Questions about this policy or about your personal information can be sent to Palm Capital Management, 23622 Calabasas Road, Suite 102, Calabasas, California 91302, by email to info@palmcm.com, or by phone at 805.727.2700.