Privacy

This Client Privacy Policy outlines how Cahill Financial Advisors, Inc. (“Cahill Financial Advisors”), an investment adviser with the U.S. Securities and Exchange Commission (“SEC”), collects, uses, discloses, and protects the non-public personal information of its clients. As an investment adviser, Cahill Financial Advisors is committed to complying with the privacy requirements under Regulation S-P and the Gramm-Leach-Bliley Act (GLBA). Non-public personal information is also referred to as “customer information” in Regulation S-P and the GLBA. The privacy and security of your personal information are of utmost importance to us, and this policy aims to explain our practices for clients in a clear and concise manner.

Information We Collect

Cahill Financial Advisors may collect various types of non-public personal information about a client, including but not limited to, the following:

• Personal Identifiers: Your name, address, email address, telephone number, date of birth, Social Security number, driver’s license or ID information, and other contact details.
• Financial Information: Account numbers and holdings, bank account and routing information, investment assets, transaction history, income sources, tax status, insurance policy information (excluding any health/medical details), and credit or debt information relevant to your financial plan.
• Profile Information: Your risk tolerance, investment objectives, employment status, family information (such as marital status or number of dependents), and other details you share with us to help tailor our advice.
• Online Information: If you use our website, we collect usage data, IP address, and other website traffic data. We do not collect contact information or other non-public personal information from our website. If you use our online client portal, we will collect login frequency data, we will collect data on which documents you have viewed, and we will collect any data that you voluntarily upload or connect to your client portal.

We collect only the information necessary to fulfill legal requirements and to effectively manage your account or meet your financial needs. We do not collect any health or medical records in connection with our investment advisory services, and we do not wish to receive any protected health information governed by HIPAA.

How We Use Your Information

We use the non-public personal information we collect for everyday business purposes in providing investment advisory and financial planning services to you. This includes, for example:

• To serve your accounts: We use your information to assist you in opening accounts, manage your portfolio, execute transactions you request or authorize, provide financial advice, and communicate with you about your accounts and financial plans.
• To operate our business: This may include maintaining internal records, auditing and compliance checks, risk management, billing, and payment processing.
• To offer services to you: We may use your contact and profile information to inform you about relevant financial products or services offered by Cahill Financial Advisors that may suit your needs. We may also invite you to client events or send newsletters or educational materials. You have the option to opt out of receiving marketing communications, as described in the “Your Choices and Rights Regarding Your Information” section.
• To fulfill legal and regulatory requirements: We may use and retain your information as needed to comply with laws and regulations (for example, verifying your identity to prevent fraud or money laundering, satisfying SEC recordkeeping rules, or responding to court orders, regulatory inquiries, or tax reporting obligations).

We will not use your personal information for any purpose that is incompatible with the purposes outlined in this Policy or that is not permitted by law. We do not sell your personal information to third parties for monetary gain. We also do not share your information for cross-context behavioral advertising purposes (as “sharing” is defined under California law).

How We Share Your Information

We understand that protecting your information is vital. We do not disclose your non-public personal information to anyone except as permitted or required by law, or as authorized by you.

We do not share your non-public personal information with non-affiliated companies for them to market to you. In other words, we do not sell or rent your personal data to third-party marketers. All information sharing is done either to service your accounts, to comply with the law, within our corporate entity, or with your express consent for specific partner relationships (such as with your insurance agent or accountant).

Below, we list the typical circumstances under which we may share your information:

• For everyday business purposes (Permitted by Law): We share your information with our employees, investment adviser representatives and other supervised persons who need the information to perform their duties and provide services to you. We may share necessary information with non-affiliated third parties who help us process transactions, maintain your accounts, or otherwise provide services on our behalf. For example, we share information with custodians who hold your assets, brokers or fund companies to execute trades, banks to process transfers, technology vendors to service your account, or mailing vendors. We also may share information as needed to protect the security of your accounts or as part of routine business operations (such as with our attorneys, auditors, or consultants). We also may share your information in the form of your signed account application for account services you request at your custodian, such as with unaffiliated third-party subadvisors or separately managed account managers. In addition, we will disclose information if required by law – for instance, to comply with subpoenas, court orders, regulatory examinations, or to report to credit bureaus or government agencies. In these cases, we share only what is necessary and only with parties obligated to keep your information confidential and use it only for the specific purpose.
• For our own marketing: We may use your information to market our services to you, such as by sending newsletters, cards or mailers. We may use third party vendors to complete these tasks. This is done directly by us; we do not disclose your information to outside companies for them to market their services to you.

How We Protect Your Information

Protecting the confidentiality and security of your information is a top priority for us. We maintain physical, electronic, and procedural safeguards in line with federal and state standards to guard your non-public personal information:

• Internally, we restrict access to your personal information to those employees, independent contractor investment adviser representatives, other supervised persons or service providers who need to know the information in order to perform their duties and provide services to you. Each of these parties is trained on the importance of confidentiality and is bound by strict policies (and often confidentiality agreements) to protect your data.
• We employ secure technologies to protect our systems: this includes computer safeguards such as firewalls, data encryption, and secure authentication procedures to prevent unauthorized access to our networks and databases. Our websites and electronic communications are secured via encryption (e.g., HTTPS and other industry standards) when you interact with us online.
• Our offices and files are secured: we use locked file cabinets or secure document storage for paper records containing non-public personal information, and our facilities have access controls. We dispose of documents containing sensitive information via secure shredding or destruction methods.
• We have an internal Written Information Security Program and policies addressing data protection, and we periodically review and update our security measures to adapt to evolving threats. In the event of a security breach that compromises your personal information, we will notify you and the appropriate authorities as required by law.
• Cahill Financial Advisors also requires any third-party service providers with whom we share information for business purposes to implement security measures that protect your data. For example, our data processing vendors and custodians must agree to confidentiality restrictions and cybersecurity standards in line with regulatory requirements.

Despite our rigorous safeguards, please understand that no system can be 100% secure. We encourage you to also do your part in protecting your information – for instance, safeguard your account statements, do not share your passwords, and notify us immediately if you suspect any unauthorized activity or if your non-public personal information has been compromised.

Your Choices and Rights Regarding Your Information

We respect your privacy choices. Federal law gives you the right to limit certain types of information sharing. State laws, such as California’s privacy laws, may provide additional rights. In some cases, these state rights may overlap with the choices described herein. We will always strive to honor the strictest applicable choice you have made, whether under federal or state law.

If you are a new client, we will collect and can begin sharing your information (in the limited ways we do) from the day you sign our investment advisory agreement or otherwise establish a relationship. If you decide to opt out of any permissible sharing, we will honor that choice as soon as we receive and process your request. For an existing client, your opt-out instruction will apply going forward. And if you are no longer our client, we may continue to maintain and share your information only as described in this Policy (for example, to comply with laws or as part of ongoing regulatory obligations), but you still retain the ability to opt out of allowable sharing at any time. Below, we explain how you can exercise those choices.

Limiting Sharing with Non-Affiliates under Federal Law (Opt-Out and Opt-In): By law, you are entitled to opt out of some sharing of your non-public personal information. Cahill Financial Advisors will not share the following categories of information without your permission:

• Non-affiliates Marketing: We will not share your information with non-affiliated third parties for them to contact you about their own products and services. In order for us to do so, we would first be required to seek your opt-in. If you do not opt in, we simply will not share your information with those parties. If you were to opt-in, you would be able to opt-out at any time, and this would be active going forward from the date of your request.

How to Opt-In for Non-Affiliate Marketing: As described within this policy, we do not share your information with non-affiliates for marketing purposes. Therefore, we currently have no option for you to opt-in to non-affiliated marketing.

Additional Privacy Rights Under State Laws: In addition to the privacy rights under GLBA and Regulation S-P, you may have certain rights under a state data protection law (depending upon your state) regarding your personal information. These rights (described below) apply in addition to your opt-out choices above, and in some cases may not apply to information already protected under GLBA. However, the policy of Cahill Financial Advisors is to be transparent and accommodative of privacy rights, so we include them here for completeness:

• Right to Know/Access: You have the right to request that we disclose the personal information we have collected about you in the past 12 months, including the categories of information, the sources of that information, the business purposes for collection, and the categories of third parties with whom we have shared or disclosed the information. You also have the right to request a copy of the specific pieces of personal information we have collected about you. Upon verifiable request, and as required by law, we will provide this information to you in a readily usable format, free of charge. Please note that in many cases, because of the GLBA exemption, the information we hold as part of providing financial services may not be subject to the state data protection law’s access requirements. If that is the case, we will let you know. Nonetheless, we aim to provide you with as much information as we are lawfully able to.
• Right to Delete: You have the right to request that we delete personal information we have collected from you. Once we receive a verified deletion request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exemption applies. Important exceptions will likely apply in a financial services context: for example, we cannot delete information that we are required to retain to comply with laws or regulations (such as SEC record retention rules), to complete transactions or services you have requested, to detect security incidents or protect against illegal or fraudulent activity, or to exercise or defend legal claims. If we must retain certain data for legal reasons, we will inform you of that in our response and will delete all other information that is not exempt. We will not use any retained data for any purpose other than the exempt reason.
• Right to Correct: If you believe that any personal information that we maintain about you is inaccurate or incomplete, you have the right to request that we correct that information. Upon verification and consideration of the request, we will correct the information as you direct, or if we dispute the accuracy, we will let you know why we cannot make the change and keep a note of your requested correction. For example, if a record we received from a third-party contains an error, we may need to verify which information is correct before updating.
• Right to Opt-Out of Sale or Sharing: The right to opt out of the “sale” of your personal information, or the “sharing” of your personal information for cross-context behavioral advertising. Cahill Financial Advisors does not sell your personal information to third parties for money. We also do not engage in sharing your information for behavioral advertising (we do not provide your data to advertising networks or data brokers for targeted ads). The limited sharing we conduct (with service providers or, with your consent, with your insurance agent, accountant or other similar professionals at your request) is either strictly for business purposes or at your direction. In any event, if you have concerns or wish to instruct us not to disclose your information beyond what is necessary for services, please contact us – we will gladly honor any request to limit data use to the extent possible.
• Right to Limit Use of Sensitive Personal Information: In some cases, you may direct a business to limit the use of “sensitive personal information” (such as Social Security numbers, financial account log-in credentials, precise geolocation, etc.) to only that which is necessary to provide services. Cahill Financial Advisors already limits the use of sensitive data to the essential purposes for which it was provided (for example, we use your Social Security number only for required tax reporting, identity verification, or account opening – we do not use it to profile you or for secondary purposes). We do not use or disclose sensitive personal information except as needed to service your account, to prevent fraud or legal violations, or as otherwise permitted by law (which are considered “necessary” purposes) or expressly authorized by you. Thus, your sensitive data is automatically handled in a limited, protected way. If you still wish to request that we further limit any use of your sensitive information, you may contact us and we will accommodate your request to the extent feasible.
• Right to Non-Discrimination: We will never discriminate or retaliate against you for exercising any of your privacy rights. This means we will not deny you services, charge you a different price, or provide a different level of service just because you exercised your rights under a state data protection law. Your relationship with us remains the same regardless of your privacy preferences. However, please note that if you do ask us to delete or restrict information, it could affect our ability to continue providing the full scope of services – for instance, we may not be able to make certain recommendations without necessary data. In such cases, we will inform you if a request could impact service, but we will not terminate or degrade your service just because of the request.

 

How to Request to Opting-Out or Limiting Sharing: You can notify us of your desire to opt out of any sharing described herein at any time. Please note, as described within this privacy policy, that you cannot opt out of certain necessary sharing, such as for everyday business operations, or sharing mandated by law, and we will notify you if this applies to your request.

• Requests for Opting-Out of Any Sharing: You can notify us of your desire to opt out of any sharing described herein at any time by contacting us. All requests must include instructions indicating which sharing practices you want to opt out of. There is no charge for opting out. We will confirm your request and ensure your preferences are honored where permitted by law. For your security, we will need to verify your identity (or authority, if an agent makes the request) before processing certain requests, particularly for access, deletion, or correction of specific pieces of information. We may ask you to confirm personal details we have on file or use other verification procedures as allowed by law. We will respond to your request within the time frames required by law (generally within 45 days, with the possibility of a 45-day extension if necessary, which we will communicate to you). There is no fee for making a request. You may contact us by phone at 952-926-1659, email us at info@cahillfa.com, or you may also send a written request to our mailing address: Cahill Financial Advisors, Inc. Attn: Operations Manager 7261 Ohms Lane, Edina, MN 55439
• Request for Opting-Out of Our Marketing Emails Only: All marketing emails sent by us can be opted out through the instructions above, or also by “Unsubscribe from this list” link at the bottom of our marketing emails, or by replying to the email with a written unsubscribe request. Please note that using this method will only serve as a request to unsubscribe specifically from marketing emails, which typically includes newsletters or other marketing announcements from our employees or Investment Advisor Representatives. Any additional or other sharing opt-out requests must use the method described above.

Updates to the Client Privacy Policy

Cahill Financial Advisors reserves the right to update this Client Privacy Policy as needed to reflect changes in our practices or applicable laws and regulations. We will notify you of any material changes, and the updated policy will be posted on our website at https://cahillfa.com/.

Conclusion

At Cahill Financial Advisors, we are committed to protecting the privacy of our clients and complying with all relevant privacy regulations. This Client Privacy Policy ensures transparency in our data practices and helps you make informed decisions about the use and sharing of your non-public personal information. We appreciate your trust in our firm and assure you that your privacy is our top priority.

Privacy Policy Rev. 04/20/2026