Privacy Notice
Privacy Notice for Individual Clients
This Privacy Notice describes how Kenora Financial, LLC (“Kenora,”) collects, uses, and protects nonpublic personal information about you in connection with the advisory services we provide as a registered investment adviser. It applies to current and former individual clients who obtain financial products or services from us for personal, family, or household purposes.
Information we collect
We collect nonpublic personal information about you in order to open and service your accounts, to comply with legal and regulatory obligations, and to provide investment advisory and related services you request. This information may include:
- Identifiers, such as your name, Social Security number, taxpayer identification number, date of birth, driver’s license number, or passport number.
- Contact information, such as your physical and mailing addresses, email addresses, and telephone numbers.
- Financial and account information, such as account numbers, custodial account details, transaction history, holdings, and other information related to your assets and liabilities.
- Other information you provide to us on account opening documents or in the course of our relationship, including information needed to verify your identity and suitability for our services.
We generally collect this information directly from you, for example through account applications and other forms you complete, as well as in the ordinary course of our advisory relationship and from your designated account custodian.
How we use and share information
We use your nonpublic personal information to:
- Establish and maintain your accounts and provide investment advisory and related services.
- Communicate with you about your accounts and our services.
- Satisfy our legal, regulatory, and contractual obligations, including required reporting and recordkeeping.
We do not sell your personal information and do not share it with third parties for their own marketing or sales purposes.
We may disclose nonpublic personal information about you, as permitted by law, to:
- Your account custodian, for purposes of opening, servicing, and maintaining your accounts and processing transactions.
- Our professional service providers that support our advisory services, such as our in‑office tax firm and other vendors that may provide administrative, operational, audit, or technology services to us.
- Our affiliates, if you engage the services of our affiliates, so that we can provide coordinated services between our affiliated entities.
- Government agencies, regulators, self‑regulatory organizations, auditors, or other parties when we believe disclosure is required or appropriate to comply with applicable law, regulation, legal process, or to protect our rights or the rights of others.
When we share information with service providers, we limit their use of your information to the purposes for which it was disclosed and expect them to safeguard it in accordance with applicable law and our contractual arrangements.
How we safeguard your information
Our Security Policy: We restrict access to nonpublic personal information about you to those individuals who need to know that information to provide products or services to you and perform their respective duties. We maintain physical, electronic, and procedural security measures to safeguard confidential client information.
Cyber Security: We maintain physical, electronic, and procedural safeguards designed to protect your nonpublic personal information from unauthorized access, use, or disclosure. These safeguards include, as appropriate:
- Access controls designed to limit nonpublic personal information to personnel who need it to perform their job responsibilities.
- Reasonable administrative, technical, and physical safeguards intended to protect against anticipated threats or hazards and unauthorized access or use.
- Processes for secure handling, storage, and disposal of records containing nonpublic personal information, in accordance with applicable recordkeeping requirements.
We periodically review and update our information security program to address changes in technology, sensitivity of data, and regulatory expectations.
If an incident occurs that involves unauthorized access to or use of your nonpublic personal information, we will conduct an investigation and take appropriate steps in accordance with our incident response procedures. Where required by law, we will notify you and any applicable regulators of a qualifying data breach, including a description of the incident and information about steps you can take to protect yourself. Internal policies and procedures are in place to address cyber security. A copy of this policy is available upon request.
Former clients
If you end your relationship with us, we will continue to protect your nonpublic personal information as described in this Privacy Notice and in accordance with our record retention and information security policies. We will retain and, when appropriate, dispose of your information consistent with applicable legal and regulatory requirements.
Your choices and inquiries
Because we do not share your nonpublic personal information with nonaffiliated third parties for their own marketing purposes, there is no separate opt‑out right for such sharing. If in the future we seek to share your information in a way that gives rise to an opt‑out right under applicable law, we will provide you with a revised notice and instructions explaining your rights.
You may contact us if you have questions about this Privacy Notice, wish to review or correct certain information we maintain about you, or want more detail about how we handle your nonpublic personal information, subject to applicable legal and regulatory limitations.
Changes to this notice and contact information
If we make any substantial changes in the way we use or disseminate confidential information, we will notify you. If you have any questions concerning this Privacy Policy, please contact us at: Kenora Financial, LLC, 1295 Rand Rd, Suite 100, Des Plaines, IL 60016; (847) 257-7200; invest@KenoraFinancial.com