Privacy Policy

Florida
Last Updated September 30, 2025

This additional data privacy rights page applies to customers in accordance with the Florida Digital Bill of Rights (FLDBOR). Under FLDBOR, you have the following privacy rights:

The Right to Know: 

This means that you have the right to request us to provide you with the following personal information, including:

  • The types of personal Information we collect about you
  • The reasons for which we collect, use, disclose, and store your personal information
  • To whom we disclose the data and the business reason(s) for doing so
  • How to delete your personal information
  • Direct us not to sell your personal information

Specifically, you also have the right to the following:

  • The categories of personal information Frank has collected about you.
  • The categories of sources from which Frank collected the personal information.
  • Frank’s business or commercial purpose for collecting or selling personal information.
  • The categories of third parties with whom Frank shares personal information.
  • The specific pieces of personal information Frank has collected about that consumer.
  • The categories of personal information that Frank has disclosed or shared about you, and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was disclosed or sold.
  • The categories of personal information that Frank disclosed about you for a business purpose.
  • The technical, operational, and security measures that are in place to protect the confidentiality, integrity, and accessibility of personal data and to reduce reasonably foreseeable risks of harm to consumers.
  • To opt out of the collection of your Personal Information from voice or face recognition technologies.

We will provide you with a listing of the Personal Information, the third parties with whom we share that data, and the purpose of that disclosure. This applies to only the Personal Information we have collected, used, shared, and stored within the last twelve (12) months. Additionally, we may provide personal information to a consumer at any time, but under law are not required to provide personal information to a customer more than twice in a 12-month period.

The Right of Deletion: 

You have the right to direct us to delete any extraneous or unnecessary Personal Information we have collected about you. This includes any Personal Information that we have collected or shared with our third-party vendors to provide you with our services. This does not, however, apply to any Personal Information you provide that is required to continue to use our services.

Right to Opt-In for Processing Sensitive Personal Information: 

During the course of providing services to you, we may require access to Sensitive Personal Information about you. This includes information relating to your racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexuality, citizenship or immigration status, genetic or biometric data, children's data, or precise geolocation data. If we need this information to continue providing services to you, we will not process the data without first advising you why we require this data, and we would only proceed after obtaining your express written consent. You are free to withdraw your consent at any time, and we will endeavor to delete the Sensitive Personal Information afterward if it is not longer required to provide you with services. 

Right of Correction:

If any of the Personal Information we have about you is correct, you may contact us to make corrections to reflect the accuracy of the Personal Information we have about you. Please note the following limitations on this right of correction:

  • This only applies to any factually incorrect Personal Information
  • Any incorrect or inaccurate Personal Information about you that originates from a third-party source cannot be corrected. For instance, if a report about your finances contains inaccurate information, we cannot correct that data. However, we may choose to annotate the records to note that the data is inaccurate and was challenged by you.
Do Not Sell: 

Under applicable state law, a “sale” of Personal Information is disclosure of your data for the purpose of cross-context behavioral advertising, which is the targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s online activity across numerous websites. We will not sell your Personal Information without your express consent. Even if you consent to the sale of your data, you have the right to opt-out and withdraw your consent.

Please note that a “sale” of Personal Information does not apply to any disclosure of data that is required for us to provide you with our services as a client or end user of SmartPath Advisors. A “sale” only applies to any secondary (optional) use of the Personal Information.

You may opt out of receiving marketing e-mail communications at any time by clicking on the unsubscribe link included at the bottom of our e-mails or sending us mail or e-mail at the address below.

Right of Non-Discrimination:

Frank will not discriminate against you if you choose to exercise your privacy rights under CCPA. This means that we will not deny you goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your rights under the CCPA.

Personal Information of Minors:

Frank does not knowingly collect the Personal Information of minors or persons under the age of eighteen (18). All users of our systems must be the age of majority.

To Exercise Your Rights:

You can exercise your request rights yourself or through an authorized agent by contacting us:

  • Sending a physical communication to:

Ryan McPherson, Chief Compliance Officer

Re: Frank

SmartPath Advisors, LLC

2451 Cumberland PKWY, STE 3954

Atlanta, GA 30339

Please make your request in writing and provide your contact information so that we may respond to your request. Once received we have up to forty-five (45) days under applicable law to process your request to delete your Personal Information. However, if your request involves a considerable amount of data and will take more time to process, we are permitted up to an additional forty-five (45) days to fulfill your request.

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