Privacy Policy

1. Introduction

ElaVar Advisory Group ("ElaVar," "we," "us," or "our") is a financial advisory firm providing credit repair, banking optimization, investment guidance, and financial education services to individual clients. We are committed to protecting your privacy and handling your personal and financial information with the highest standard of care.

This Privacy Policy explains what information we collect, how we use it, who we share it with, and your rights regarding your information. It applies to our client portal at elavaradvisory.com and all associated services.

By creating an account or using our services, you agree to the terms of this Privacy Policy.

2. Information We Collect

2.1 Information You Provide Directly

When you create an account or use our services, we collect:

• Full name, date of birth, and contact information (email address, phone number)
• Residential address
• Financial information including income range, employment status, and financial goals
• Credit-related information including current credit score range, credit issues, and debt information
• Investment experience, risk tolerance, and portfolio preferences
• Identity verification information as required by applicable law
• Communications you send to your advisor through the portal messaging system
• Documents you upload to your secure document vault

2.2 Information Collected Through Plaid

If you choose to connect your bank accounts through our Plaid integration, we receive:

• Bank account numbers and routing numbers (for account verification purposes only)
• Account balances and transaction history
• Account holder name and address as reported by your financial institution

You authorize ElaVar to receive this information by completing the Plaid Link flow. You may disconnect your bank accounts at any time through your account settings, at which point we will revoke our access to your account data.

2.3 Information Collected Automatically

When you use our portal, we may automatically collect:

• Log data including your IP address, browser type, and pages visited
• Device information including device type and operating system
• Session activity including login times and features accessed

3. How We Use Your Information

We use the information we collect to:

• Provide personalized financial advisory services, credit repair guidance, and investment recommendations
• Connect your bank accounts and display your financial data within your client portal
• Communicate with you about your account, services, and financial progress
• Generate dispute letters and credit repair documentation on your behalf
• Calculate your Financial Health Score and track your financial progress over time
• Send you educational content, service updates, and account notifications
• Comply with legal obligations and regulatory requirements applicable to financial advisory services
• Protect against fraud, unauthorized access, and other security threats

We do not use your information for advertising, and we do not sell your personal information to third parties for marketing purposes.

4. How We Share Your Information

4.1 Service Providers

We share your information with trusted service providers who help us deliver our services, under strict confidentiality obligations:

These providers are contractually prohibited from using your information for any purpose other than providing services to ElaVar.

4.2 Legal Requirements

We may disclose your information if required to do so by law, court order, or government regulation, or if we believe disclosure is necessary to protect the rights, property, or safety of ElaVar, our clients, or others.

4.3 What We Never Do

• We never sell your personal or financial information to data brokers or third parties
• We never share your information with advertisers
• We never use your bank account data for purposes other than providing your advisory services
• We never share your credit report data without your explicit consent

5. Data Retention

We retain your personal information for as long as your account is active and for 7 years after account closure, in accordance with financial recordkeeping requirements under applicable federal and state law.

Bank account data received from Plaid is retained for as long as you maintain a connected account. When you disconnect a bank account, we revoke our Plaid access token and delete the associated account data within 30 days.

You may request deletion of your account and associated data at any time by contacting privacy@elavaradvisory.com. We will process your request within 30 days, subject to any legal retention obligations.

6. Data Security

We implement industry-standard security measures to protect your information:

• All data transmitted between your browser and our servers is encrypted using TLS 1.2 or higher
• All data stored in our database is encrypted at rest using AES-256 encryption
• Your account is protected by password authentication and multi-factor authentication (MFA), which is required for all accounts
• Access to your data is restricted to your designated advisor and enforced through database-level security policies
• Plaid access tokens are stored securely in our encrypted database and are never exposed in your browser
• All administrative access to production systems requires multi-factor authentication

While we implement strong security measures, no method of transmission over the internet is 100% secure. We encourage you to use a strong, unique password and enable biometric authentication when prompted.

7. Your Rights and Choices

7.1 Access and Correction

You have the right to access the personal information we hold about you and to request corrections to any inaccurate information. You can view and update most of your information directly in your client portal under Profile Settings.

7.2 Data Deletion

You have the right to request deletion of your personal information. To submit a deletion request, contact privacy@elavaradvisory.com. We will process your request within 30 days, subject to any legal retention obligations.

7.3 Bank Account Disconnection

You may disconnect your linked bank accounts at any time through your portal settings. Upon disconnection, we will revoke our Plaid access and delete associated account data within 30 days.

7.4 Communication Preferences

You may opt out of non-essential communications at any time by contacting us or using the unsubscribe link in any marketing email. You cannot opt out of essential account and security notifications.

7.5 California Residents (CCPA)

California residents have additional rights under the California Consumer Privacy Act, including the right to know what personal information we collect and how it is used, the right to deletion, the right to opt out of the sale of personal information (we do not sell personal information), and the right to non-discrimination for exercising your rights. To exercise your CCPA rights, contact privacy@elavaradvisory.com.

8. Children's Privacy

Our services are intended for adults 18 years of age and older. We do not knowingly collect personal information from children under 18. If we become aware that we have collected information from a child under 18, we will delete it promptly. If you believe we have inadvertently collected information from a minor, please contact privacy@elavaradvisory.com.

9. Third-Party Links and Services

Our portal may contain links to third-party websites or integrate with third-party services. This Privacy Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you use.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will notify you by email and by posting a prominent notice in your client portal at least 30 days before the changes take effect. Your continued use of our services after the effective date constitutes acceptance of the updated policy.

The current version of this policy is always available at elavaradvisory.com/privacy.

11. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please reach out:

We will respond to all privacy inquiries within 10 business days.