Information Collection

Evoke Advisors may collect personal information through submission of account documentation and contact information on forms completed or approved by the client, or client’s authorized representative. Such information could include the client’s name, e-mail and postal address, phone number, Social Security number, assets, income, financial needs and goals, account balances and transactions, including those with unaffiliated third parties.

Information Use

From time to time, Evoke Advisors may disclose personal information collected from clients as may be required to service your account to third-party service providers that facilitate the operation of some areas of our investment advisory business, and Evoke Advisors may also use such information in the account intake process, including conducting anti-money laundering screening. We require any third-party service providers to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them. We do not share or sell personal information to affiliated or unaffiliated third parties for the purpose of marketing or promotion.

We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

• To provide, operate and improve our services and our website;
• To answer your inquiries;
• To provide support and maintenance;
• To respond to your requests and feedback;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• To comply with legal obligations; and
• With your consent.

Safeguards

Evoke Advisors uses the following measures to protect the privacy of clients. All personal information in our computers is protected from unauthorized access by a secure firewall and database architecture. In instances where personal information is exchanged via the internet, electronic and procedural methods to safeguard this exchange are used.

It is the policy of Evoke Advisors to ensure so called “consumer report information” (such as personal information about a client, e.g., Social Security number) is protected, maintained and disposed of in ways that ensure such information is safeguarded from unauthorized uses or disclosures. Evoke Advisors will take reasonable measures to dispose of personal information so that it cannot be read or reconstructed for unauthorized use. Evoke Advisors will determine the appropriate method of disposal on an as needed basis.

Service Providers

Evoke Advisors may have relationships with non-affiliated third parties that require us to share customer information in order for the third party to carry out its services for us.

Processing and Servicing Transactions

Evoke Advisors may share information when it is necessary to effect, administer, or enforce a transaction for our clients or if a client initiates a request for us to share information with an outside party. All requests by clients must be received in writing from the client.

Sharing as Permitted or Required by Law

Evoke Advisors may disclose information to non-affiliated third parties as allowed by law. For example, this may include a disclosure in connection with a subpoena or similar legal process, a fraud investigation, recording of deeds of trust and mortgages in public records, an audit or examination, or the sale of an account to another financial institution.

Cookies & Similar Technologies

We use cookies and related technologies (“Cookies”) to provide services, gather information when users navigate through our website to enhance and personalize the experience, to understand usage patterns, and to improve our Sites, products, and Services.

Types of Cookies: We use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on our Site can be grouped into the following categories:

• Strictly Necessary: These Cookies are necessary for the Site to work properly. They include any essential authentication and authorization Cookies for our Site.
• Functionality: These Cookies enable technical performance and allow us to remember the choices you make while browsing our Site, including any preferences you set. They also include sign-in and authentication Cookies and IDs that enable you to return without additional sign-in.
• Performance/Analytical: These Cookies allow us to collect certain information about how you navigate the Site and services running on your device. They help us understand which areas you use and what we can do to improve them.
• Advertising: These record your visit to our Sites, the pages you have visited and the links you have followed to recognize you as a previous visitor and to track your activity on the Sites and other websites you visit. These Cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our Sites. You can delete these cookies via your browser settings.

California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”) 

You may have certain rights granted to you if your personal information is protected by the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2022:

You may have the right to request that we delete any personal information that we have about you. You may call us at (424) 372-1776 or email us at bwaters@evokeadvisors.com with “CCPA Right to Delete” in the subject line and in the body of your message to exercise this right.

You may have the right to request from us:

• the specific pieces of personal information that we have about you;
• the categories of personal information we have collected about you;
• the categories of sources from which your personal information is collected;
• the categories of your personal information that we have sold or disclosed for a business purpose about you;
• the categories of third parties to whom your personal information was sold or disclosed for a business purpose; and
• the business or commercial purpose for collecting or selling your personal information.

You may call us at (424) 372-1776 or email us at bwaters@evokeadvisors.com with “CCPA Right to Know” in the subject line and in the body of your message to exercise this right.

There are circumstances where we are not required to comply with consumer requests and we will let you know if one of those situations arises.

We do not sell your personal information.

You also have the right to request correction of any inaccurate personal information we may have in our possession, as well as the right to limit and/or restrict the use of sensitive personal data.

We reserve the right to verify your identity before we process any request relating to your personal information. We verify identify by comparing information we have on file against information you may provide us.

California residents may not be discriminated against for exercising any of the rights described above.

Summary of Data Disclosed to Third Parties

In the preceding twelve (12) months, we may have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below. We do not “sell” or “share” your information as those terms are defined in the CCPA.