Security & Data Policy

Acknowledgments

Each acceptance is an unticked checkbox or a signed acceptance on its own page. The record stores the version, the time, and the person.

Last updated October 4, 2026, version 1.0

applicant-consent-1.0

Applicant consent

Required checkbox on the firm application. Not a binding agreement.

Consent to public-source checks and a verification call, and confirmation that the policies were read.

I consent to Advolo running public-source checks on my firm and contacting our CCO for a verification call, and I have read the Privacy Policy and Security & Data Policy.

terms-1.0 and privacy-1.0

CCO account creation

Required checkbox on the account-creation link, before the account is created.

Acceptance of the Terms of Use and the Privacy Policy by the person creating the firm account.

I have read and accept the Terms of Use and the Privacy Policy.

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Platform Agreement

Accepted by the CCO on its own page during Oversight setup, before the firm can go live.

The firm’s agreement that Advolo is recommendation-only technology.

This Platform Agreement is between AdvoloTech (“Advolo”) and the registered investment adviser firm named in the firm profile. The firm’s chief compliance officer accepts it for the firm. Advolo provides workflow technology for allocation recommendations on held-away accounts. Advolo does not take custody of client assets, does not place trades, and does not receive authority to trade. Advisors on this platform send allocation recommendations. They do not trade, hold assets, or log in to client accounts through Advolo. The client decides whether to act, and places any trades in their own account. Advolo is the technology provider. Advolo is not the firm’s investment adviser and is not a custodian. The firm remains responsible for its advice, its disclosures, its client agreements, and its supervision. Opening an account is not a certification of the firm. A person at Advolo approves the firm before this account exists. Public-source diligence checks do not approve a firm. The firm cannot invite advisors until it is live, which includes this acceptance, the Security & Data Agreement, and the rest of the required setup. The Security & Data Policy and the Privacy Policy, each version 1.0 as of October 4, 2026, describe the information Advolo collects and the controls it operates. The firm accepts those practices for the information it and its clients place on the platform. This acceptance is recorded with the signer’s name, title, the version, the time, and the account that accepted it. The record is not edited. A later version is a new acceptance.

security-data-agreement-1.0

Security & Data Agreement

Accepted by the CCO on its own page during Oversight setup, before the firm can go live.

The firm’s agreement to the security and data practices.

This Security & Data Agreement is between AdvoloTech (“Advolo”) and the registered investment adviser firm named in the firm profile. The firm’s chief compliance officer accepts it for the firm. It is the firm-facing form of the public Security & Data Policy, version 1.0. Advolo stores the firm information collected at application and during setup, and the audit record of actions on the platform. When client onboarding is open, Advolo will store fund names a client provides so an advisor can prepare an allocation recommendation. Advolo does not collect Social Security numbers, account numbers, or client-account credentials, and it does not ask for trading authority or custody. Advolo does not sell personal information and does not use it for advertising. A firm cannot read another firm’s rows. The database enforces that separation with row-level security. Access inside a firm follows least-privilege roles. Every state-changing action writes an append-only audit row tied to a named person, or to the applicant when the person has no account. Accepted agreements are not edited. Hosting and the database are provided by Vercel and Supabase, which encrypt data in transit and at rest. Transactional email is sent through Resend. Stripe and an e-signature provider are planned and are not in use. Retention follows the schedule in the Security & Data Policy: firm recommendation and agreement records for the relationship plus 7 years; Advolo’s own approved-firm vetting file for the relationship plus 10 years; applications that are not approved for 10 years from the decision; this acceptance for the term plus 10 years. Audit rows follow the record they belong to. If Advolo learns of unauthorized access to the firm’s or a client’s information, Advolo will notify the firm’s compliance contact and keep a record of that notice. A person approves firms and the firm’s client packet. The Security Officer is Mason, the owner of Advolo. This acceptance is recorded with the signer’s name, title, the version, the time, and the account that accepted it. The record is not edited.

advisor-invite-ack-1.0

Advisor invitation

Text is ready. The invite acceptance screen is not on this branch yet.

The advisor accepts the Terms of Use, acknowledges the firm’s approved client packet, and confirms recommendation-only use.

I accept the Terms of Use. I acknowledge my firm’s approved client packet, and I will use Advolo for recommendations only. I do not place trades, hold client assets, or sign in to client accounts through Advolo.

client-onboarding-ack-1.0

Client onboarding

Text is ready for a future signup checkbox, before any fund upload.

The client accepts the terms and privacy notice and confirms that they place any trades themselves.

I accept the Terms of Use and the Privacy Policy. Advolo provides recommendations only. I place any trades myself. Advolo never trades or holds my assets.

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