At Dew Wealth Management, LLC (referred to as “Dew Wealth” or “we” or “us” in this privacy policy), we respect the privacy of our users and are committed to protecting the information you provide to us. This privacy policy describes how we collect, use, and share information about you when you use our site (the “Site”).

Last updated: [DATE]

How this policy relates to our client privacy notice: This Privacy Policy governs the Site. If you become a client of Dew Wealth Management, information we collect in connection with providing advisory services is also governed by the separate privacy notice we deliver to clients under federal law. Where the two overlap, the client notice governs the information covered by it.

1. Information We Collect

1.1 Information You Provide: We collect information you give us directly, such as your name, email address, phone number, and mailing address. You may provide this when you submit a request for information or services, complete a form, schedule a meeting, sign up for our newsletter, participate in a promotion, or contact us with a question or concern.

1.2 Content You View: Our Site contains videos and other proprietary content about financial topics. We may collect information about the content you view, such as its title, length, and the date you viewed it.

1.3 Content You Post: Where the Site allows you to post messages or comments, we collect the content you post, including text, images, and video.

1.4 Information Collected Automatically: When you use the Site, we and our service providers automatically collect certain information, including:

• Device and connection data: IP address, browser type and version, operating system and version, device type, screen and viewport size, pixel ratio, touch support, user agent, language, locale, and time zone.
• Usage data: pages viewed, links clicked, referring website, time spent on pages, and the dates and times of your visits.
• Online identifiers, including advertising click identifiers: When you arrive at the Site from an advertisement or a campaign link, we store campaign parameters (such as utm_source, utm_medium, utm_campaign, utm_term, and utm_content) and advertising click identifiers issued by advertising platforms (such as Google’s gclid, Meta’s fbclid, and Microsoft’s msclkid) in cookies on your browser. We use these to understand which marketing efforts bring people to the Site and to measure whether those efforts result in an inquiry.
• A persistent visitor record: We assign your browser a randomly generated visitor identifier and store it alongside a visit count, first-seen and last-seen timestamps, your first-touch attribution (the channel, campaign, click identifier, landing page, and referring site of your first visit), and the device and environment data listed above. This record persists across visits until the cookie expires or you clear it. It does not contain your name or contact details, but if you later submit a form it may be associated with the contact record you create.
• Session recordings: We use a session-replay tool that records how you move, scroll, and click through pages so we can identify where the Site is confusing or broken. It is configured to mask text you type into fields.
• Form interactions: Our CRM automatically captures submissions from forms on the Site and associates them with your visit history.

We collect this information using cookies, pixels, tags, session-replay scripts, and browser storage. Our Cookie Policy names every provider and cookie in use and describes your choices.

1.5 Information We Do Not Intentionally Collect: We do not ask for, and ask that you not submit through the Site, Social Security numbers, account numbers, credentials, health information, or other sensitive personal information. We do not knowingly collect precise geolocation data or biometric information through the Site.

2. How We Use Your Information

2.1 To Provide and Respond: To deliver the Site’s features and content, respond to your inquiries, and fulfill your requests.

2.2 To Improve the Site: To analyze how the Site is used, understand which content is useful, diagnose problems, and improve design and performance.

2.3 To Communicate With You: To send you information about our services, educational content, events, and promotions. You can opt out of marketing messages at any time; see Section 6.

2.4 For Marketing Measurement and Advertising: To measure the performance of our marketing, attribute inquiries to the campaign or channel that produced them, and reach people who may be interested in our services.

2.5 For Security and Integrity: To protect the Site against fraud, abuse, automated attacks, and unauthorized access.

2.6 For Legal and Compliance Purposes: To comply with applicable laws, regulations, and regulatory recordkeeping obligations, to respond to legal process and governmental requests, and to protect our rights, safety, and property and those of others.

2.7 User-Generated Content: Content you post may be used for promotional purposes, to improve the Site, or for other legitimate business purposes. Except as described in Section 3, we will not disclose personal information associated with your posted content without your consent.

3. How We Disclose Your Information

We do not sell your personal information for money.

We do share information with the categories of recipients below. Some U.S. state privacy laws define “sale” and “sharing” broadly enough that disclosures to analytics and advertising providers may fall within those definitions. Section 7 explains how to opt out.

3.1 Service Providers: We use third parties to operate the Site and our marketing, under contracts that limit their use of the information to the services they provide to us. These currently include:

3.2 Advertising and Retargeting Partners: We use advertising platforms to measure campaign performance and to show our services to people who have visited the Site. Through cookies and pixels on our pages, these platforms receive online identifiers and information about your visit, and may combine it with data they already hold about you. Some state privacy laws treat these disclosures as “sharing” for targeted advertising or as a “sale.” You can opt out; see Section 7. The advertising and retargeting platforms active on the Site are Meta (Facebook, Instagram), Google Ads, Microsoft Advertising, LinkedIn, AdRoll, Outbrain, and Taboola.

3.3 Legal and Regulatory Disclosure: We may disclose information to regulators, law enforcement, government officials, or other third parties where required by law, regulation, subpoena, or court order, or where reasonably necessary to protect legal rights or safety.

3.4 Content You Post: Content you post is generally viewable by other users of the Site.

3.5 Business Transfers: In a merger, acquisition, financing, or sale of assets, information may be transferred as part of the transaction. We will notify you by email or a prominent notice on the Site of any resulting change in how your personal information is used.

4. How Long We Keep Information

We keep personal information for as long as needed for the purposes described in this policy, and then for as long as required by our legal, regulatory, and recordkeeping obligations as an SEC-registered investment adviser. Cookie lifetimes are described in our Cookie Policy. Where information is no longer needed and no retention obligation applies, we delete it or de-identify it.

5. Data Security

We maintain administrative, technical, and physical safeguards designed to protect information from unauthorized access, use, and disclosure. These include encryption of information in transit, access controls limiting access to authorized personnel, and monitoring of our systems.

No method of transmission over the internet or electronic storage is completely secure. While we work to protect your information, we cannot guarantee absolute security.

6. Your Choices

6.1 Marketing Communications: You can opt out of marketing emails by using the unsubscribe link in any message, or by contacting us using the details in Section 9. We may still send you messages relating to a request you made or a relationship you have with us.

6.2 Cookies and Similar Technologies: You can manage cookies through your browser settings and through the controls described in our Cookie Policy. Blocking some cookies may affect how the Site works.

6.3 Analytics: You can opt out of Google Analytics across websites using Google’s browser add-on, available from Google.

6.4 Advertising Preferences: Advertising platforms provide their own controls for personalized advertising. You can also use industry opt-out tools offered by the Digital Advertising Alliance and the Network Advertising Initiative.

7. U.S. State Privacy Rights

Several U.S. states give residents rights over their personal information. These rights, and which of them apply to you, depend on your state of residence.

7.1 Rights: Subject to applicable law and to verification of your identity, you may have the right to:

• Know and access the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the categories of third parties to whom we disclose it.
• Correct inaccurate personal information we maintain about you.
• Delete personal information we have collected from you.
• Obtain a portable copy of personal information you provided to us.
• Opt out of targeted advertising, of any “sale” or “sharing” of your personal information as those terms are defined by applicable state law, and of profiling in furtherance of decisions producing legal or similarly significant effects.
• Not be discriminated against for exercising these rights. We will not deny you services, charge you a different price, or provide a different level of quality because you exercised a privacy right.

Some information is exempt from these rights, including information subject to federal financial privacy law and information we are required to retain under securities regulations.

7.2 How to Exercise Your Rights: Email privacy@dewwealth.com with the subject line “Privacy Rights Request,” or write or call us using the details in Section 9. Tell us which right you want to exercise and the state you reside in. We will acknowledge your request and respond within the time required by applicable law. We may need to verify your identity before acting, and we may ask you for information sufficient to do so. We will not use that information for any other purpose.

7.3 Authorized Agents: You may use an authorized agent to submit a request on your behalf. We may require written proof of the agent’s authority and may require you to verify your own identity directly with us.

7.4 Appeals: If we decline your request, you may appeal that decision by replying to our response or emailing privacy@dewwealth.com with the subject line “Privacy Appeal.” We will inform you in writing of the outcome and the reasons for it. If your appeal is denied, you may contact your state attorney general.

7.5 Browser Opt-Out Signals: Some browsers and extensions send an opt-out preference signal such as Global Privacy Control (GPC) or Do Not Track. We do not currently detect or respond to these signals automatically. To opt out, use the browser and advertising controls described in Section 6, or submit a request as described in Section 7.2.

8. Additional Information

8.1 Children’s Privacy: The Site is not intended for individuals under 18, and we do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, contact us and we will take appropriate steps to delete it.

8.2 Users Outside the United States: The Site is hosted in the United States and intended for users in the United States. If you access the Site from elsewhere, your information will be transferred to and processed in the United States.

8.3 Third-Party Links: The Site links to third-party websites, including social media platforms, that we do not control. Those sites have their own privacy policies, which we encourage you to review. We are not responsible for their content or privacy practices.

8.4 Changes to This Policy: We may update this Privacy Policy. We will post the revised policy on the Site and update the “Last updated” date above. If we make material changes to how we use personal information, we will provide additional notice.

9. Contact Us

Questions, concerns, or requests about this Privacy Policy or our handling of your personal information:

Dew Wealth Management, LLC
8888 E. Raintree Dr., Suite 110
Scottsdale, AZ 85260
(480) 614-9119
privacy@dewwealth.com