Your financial life is the most personal information you have. We treat it that way. This notice explains exactly what we collect, why we collect it, who ever sees it, and how long we keep it.
Effective September 9, 2026 · Reviewed annually
1. Scope of This Notice
Broadway Advisor Group, LLC (“Broadway,” “we,” “us,” or “our”) is an investment adviser registered with the U.S. Securities and Exchange Commission. Registration does not imply a certain level of skill or training. This Privacy Policy and Privacy Notice describes how we collect, use, share, protect, and retain personal information about prospective clients, clients, former clients, website visitors, and other individuals who interact with us.
This notice is delivered in satisfaction of our obligations under Regulation S-P (17 C.F.R. Part 248) and Regulation S-AM under the Gramm-Leach-Bliley Act, the SEC’s Regulation S-ID identity theft red flags rules, the New York Stop Hacks and Improve Electronic Data Security (SHIELD) Act (N.Y. Gen. Bus. Law §§ 899-aa and 899-bb), and applicable state privacy law. It applies to broadwayadvisorgroup.com, all subdomains and gated portals we operate, and to advisory relationships conducted offline.
2. Information We Collect
We collect only the information reasonably necessary to provide advisory services and to satisfy legal and regulatory obligations.
Information you provide. Name, mailing and email address, telephone number, date of birth, Social Security or taxpayer identification number, government identification, employment and income information, net worth, investment objectives, risk tolerance, beneficiary and household information, and accreditation or qualified purchaser attestations.
Information from your transactions. Account balances, holdings, transaction history, contributions and distributions, advisory fees, and account activity with us and with your custodian.
Information from third parties. Data received from custodians (including Fidelity and Interactive Brokers), account aggregation providers, consumer reporting or identity verification vendors, your other professional advisers where you authorize it, and publicly available sources.
Information collected automatically. IP address, device and browser type, pages viewed, referring URL, timestamps, and similar technical data collected through cookies and server logs.
Communications. Emails, secure messages, scheduling requests, inquiry forms, and — where permitted and disclosed — recordings or logs of calls and text messages retained for books-and-records purposes.
3. How We Use Information
Delivering, administering, and personalizing investment advisory and financial planning services.
Opening, maintaining, and servicing accounts held at third-party custodians.
Determining eligibility for private market opportunities, including accredited investor and qualified purchaser verification.
Calculating and billing advisory fees.
Complying with the Investment Advisers Act of 1940, anti-money-laundering and USA PATRIOT Act obligations, tax reporting, subpoenas, examinations, and other legal requirements.
Detecting, preventing, and responding to fraud, identity theft, and security incidents.
Communicating with you about your accounts, our services, market commentary, and firm updates.
Improving website performance, content, and accessibility.
4. What We Never Do
We do not sell your personal information. We never have and we never will.
We do not sell, rent, or trade personal information to any third party for money or other valuable consideration.
We do not share personal information with non-affiliates for their own marketing purposes.
We do not use client information to place trades for our own account or for any purpose adverse to your interests.
We do not permit our service providers to use your information for any purpose other than the services they perform for us.
5. When We Share Information
We disclose personal information only as permitted or required by law, and only to the extent necessary. Categories of recipients include:
Custodians and brokers who hold and execute in your accounts.
Service providers under written contract — portfolio accounting, customer relationship management, secure document storage, email and communications archiving, scheduling, identity verification, and cloud infrastructure — each bound by confidentiality and permitted-use restrictions.
Professional advisers such as your accountant, attorney, or trustee, at your direction or with your consent.
Regulators and law enforcement, including the SEC and state securities regulators, in connection with examinations, subpoenas, court orders, or legal process.
Fund sponsors, issuers, and administrators where you elect to subscribe to a private offering and the information is required to process the subscription.
Successors in interest in the event of a merger, acquisition, or transfer of the advisory business, subject to this notice.
Because we do not share nonpublic personal information with non-affiliates other than as permitted by Regulation S-P, federal law does not provide an opt-out right for these disclosures. You may still contact us with any restriction request and we will honor it where we can continue to service your account.
6. How We Protect Information
We maintain a written information security program with administrative, technical, and physical safeguards reasonably designed to protect the confidentiality, integrity, and availability of personal information, as required by Regulation S-P’s safeguards rule and the New York SHIELD Act.
Encryption of personal information in transit and at rest.
Role-based access controls limiting access to personnel with a legitimate business need.
Multi-factor authentication for advisory and administrative systems.
Row-level database access controls and tamper-evident audit logging of sensitive actions.
Vendor due diligence and contractual security obligations for all service providers.
Periodic risk assessments, employee training, and an incident response plan tested against realistic scenarios.
Secure disposal of records that are no longer required to be retained.
No system is perfectly secure. If an incident occurs, we will investigate promptly and provide notice to affected individuals and to the New York State Attorney General, Department of State, and Division of State Police, and to any other regulator, in the manner and within the timeframes required by law — including the SEC’s Regulation S-P incident response and customer notification requirements.
7. Retention
We retain books and records, including client communications and account documentation, for at least five years from the end of the fiscal year in which they were created — the first two years in an easily accessible place — as required by Rule 204-2 under the Investment Advisers Act. Certain organizational records are retained longer. When information is no longer required for a business, legal, or regulatory purpose, it is securely destroyed.
8. Your Rights and Choices
Access and correction. You may request a copy of the personal information we hold about you and ask us to correct inaccuracies.
Deletion. You may request deletion of information we are not required to retain under securities recordkeeping rules.
Marketing communications. You may opt out of firm marketing emails at any time using the unsubscribe link or by contacting us. Service and regulatory communications will continue.
Affiliate marketing. Consistent with Regulation S-AM, we do not use eligibility information received from affiliates to market to you.
Do Not Track. Our site does not respond to browser Do Not Track signals, as no uniform standard exists.
State privacy rights. Residents of states with comprehensive privacy statutes may have additional rights. Much of the information we hold is exempt under the GLBA financial-data exemption; where an exemption does not apply, we will honor verified requests.
To exercise any right, email info@broadwayadvisorgroup.com or call 518.477.3626. We will verify your identity before responding.
9. Cookies and Website Analytics
We use strictly necessary cookies for authentication, session management, and security, and limited analytics to understand aggregate site usage. We do not use advertising cookies, cross-site tracking pixels, or data brokers. You may block or delete cookies in your browser settings; gated areas of the site, including client and private market portals, will not function without session cookies.
10. Gated and Private Market Areas
Access to non-public areas of this site is restricted to invited and verified individuals. Information submitted in eligibility or verification flows — including accreditation and qualified purchaser attestations — is used solely to determine eligibility, maintain required records, and administer the relationship. Nothing on this website is an offer to sell or a solicitation of an offer to buy any security. Private market investments are illiquid, speculative, involve the risk of total loss, and are available only to investors who meet applicable eligibility standards.
11. Children
Our services and website are not directed to individuals under 18, and we do not knowingly collect personal information from children. Information about minor beneficiaries or custodial account holders is collected from the adult account owner and treated under this notice.
12. Third-Party Sites
Links to custodian portals and other third-party websites are provided for convenience. Those sites are governed by their own privacy policies and terms, and we are not responsible for their content or practices.
13. Changes to This Notice
We deliver this notice at the start of an advisory relationship and annually thereafter for as long as the relationship continues. If we make a material change, we will post the revised notice here with a new effective date and, where required, provide it to you directly.
Broadway Advisor Group, LLC is an investment adviser registered with the U.S. Securities and Exchange Commission. Registration does not imply a certain level of skill or training. Nothing on this page constitutes investment, legal, or tax advice. This notice is provided for informational purposes and does not create any contractual rights beyond those required by applicable law.
