Last Updated: October 16, 2026

1. Introduction and Scope

Latigo Peak Partners, LLC (“Latigo Peak,” “we,” “us,” or “our”) respects your privacy. This Website Privacy Policy (“Policy”) explains how we collect, use, disclose, and protect personal information when you visit or interact with www.latigopeak.com and any other website, page, or online form that links to this Policy (collectively, the “Website”).

This Policy applies to information collected through the Website. It does not replace the privacy notice we provide to clients under the Gramm-Leach-Bliley Act and SEC Regulation S-P (our “Client Privacy Notice”), which governs nonpublic personal information we collect in connection with providing financial products and services. If you are or become a client, please also review our Client Privacy Notice, available at https://www.latigopeak.com/client-privacy-notice/ and described in Section 8 below. If there is a conflict between this Policy and our Client Privacy Notice regarding client nonpublic personal information, the Client Privacy Notice controls. Our Cookies Policy, available at https://www.latigopeak.com/cookies-policy/, provides additional detail about the cookies and similar technologies we use on the Website. If this Policy conflicts with our Cookies Policy, this Policy controls, except that the Cookies Policy controls with respect to the specific cookies and similar technologies we use and how you can manage them.

By using the Website, you acknowledge the practices described in this Policy. If you do not agree with this Policy, please do not use the Website.

2. Who We Are and How to Contact Us

Latigo Peak Partners, LLC is a wealth management firm and an investment adviser registered with the U.S. Securities and Exchange Commission. Registration does not imply a certain level of skill or training. Latigo Peak is the business responsible for the personal information collected through the Website and, where applicable law uses the term, the “controller” of that information.

If you have questions about this Policy or our privacy practices, or wish to exercise a privacy right, please contact us:

• Mail: Latigo Peak Partners, LLC, Attn: Privacy Officer, 3001 PGA Blvd, Suite 110, Palm Beach Gardens, FL 33410
• Email: compliance@latigopeak.com
• Toll-free telephone: 833-452-8446

3. Personal Information We Collect

“Personal information” means information that identifies, relates to, describes, or could reasonably be linked to you or your household. The categories we collect through the Website depend on how you interact with us and may include:

Sensitive personal information. We do not request, and ask that you not submit through the Website, Social Security numbers, account numbers, account credentials, government identification numbers, or similar sensitive information. If you become a client, we will collect that information through secure onboarding channels governed by our Client Privacy Notice.

4. Sources of Personal Information

We collect personal information from the following sources:

• Directly from you, when you complete a form, request a consultation, email or call us, or otherwise provide information through the Website.
• Automatically, when you use the Website, through cookies, pixels, web beacons, server logs, and similar technologies. See our Cookies Policy for details.
• From third parties, such as our affiliates, service providers who operate or analyze the Website, professional networking and social media platforms (to the extent you make information public or interact with our pages), referral sources, and publicly available sources. Where permitted by law and applicable agreements, our advisers may also bring limited client contact information from their prior firm when they join Latigo Peak.

5. How We Use Personal Information

We use the personal information we collect for the following business purposes:

• Providing and improving the Website and our services, including operating, maintaining, and personalizing the Website, and developing new features and offerings.
• Responding to inquiries, including responding to consultation requests and evaluating whether our services may be suitable for you.
• Marketing and communications, including sending marketing communications and information about our services where permitted by law, and, through our advertising partners, showing you Latigo Peak advertisements on other websites and measuring their effectiveness. You may opt out of marketing emails at any time by contacting us, and you may opt out of interest-based advertising as described in Section 13.
• Analytics, including understanding how visitors use the Website and measuring the effectiveness of our content and communications.
• Legal and regulatory compliance, including meeting our recordkeeping, supervision, and other obligations under the Investment Advisers Act of 1940 and other applicable laws, and responding to regulatory examinations, subpoenas, and lawful requests.
• Fraud prevention and security, including detecting, investigating, and preventing security incidents, fraud, and other unlawful activity, and protecting the rights, property, and safety of Latigo Peak, our clients, and others.
• Internal business operations, including auditing, recordkeeping, risk management, and in connection with a merger, acquisition, reorganization, or sale of all or part of our business.

We may also use information that has been aggregated or de-identified so that it no longer reasonably identifies you for any lawful purpose. We will maintain and use de-identified information without attempting to re-identify it, except as permitted by law.

6. How We Disclose Personal Information

We do not sell personal information for money. However, as described below, we share personal information with advertising partners for cross-context behavioral advertising, which may be considered a “sale,” “sharing,” or “targeted advertising” under certain state privacy laws. We may disclose personal information to the following categories of recipients for the purposes described in this Policy:

• Affiliates, including our parent company, ASO Meridian Holdings, LLC, and other entities under common ownership or control, for operational, administrative, and compliance purposes.
• Service providers, who perform services on our behalf, such as website hosting and development, information technology and cybersecurity management, cloud storage and productivity software, email delivery, customer relationship management, analytics, and professional services. Our service providers are contractually required to protect personal information and to use it only to perform services for us. The categories of service providers we use are described in Section 7.
• Business partners, such as custodians, broker-dealers, or other financial institutions, only as needed to respond to your request or provide services you request.
• Professional advisers, such as attorneys, accountants, auditors, and compliance consultants, subject to confidentiality obligations.
• Regulators, law enforcement, and other parties as required by law, including the SEC, state securities regulators, and courts, and to comply with legal process, enforce our agreements, or protect rights, property, or safety.
• Parties to a corporate transaction, such as a successor or acquirer in connection with a merger, acquisition, financing, reorganization, or sale of assets.
• Advertising and social media partners, who collect information through cookies and pixels on the Website to deliver and measure Latigo Peak advertisements, as described in this Section and in our Cookies Policy.
• Others with your consent or at your direction.

We share personal information, such as online identifiers, IP address, and information about your activity on the Website, with advertising and social media partners through cookies, pixels, and similar technologies so that we can show you Latigo Peak advertisements on other websites and measure their effectiveness. Under certain state privacy laws, this may be considered “sharing” for cross-context behavioral advertising, a “sale,” or “targeted advertising.” You may opt out at any time by clicking the “Do Not Sell or Share My Personal Information” link in the Website footer or visiting Do Not Sell or Share My Personal Information, by rejecting advertising cookies through “Cookie Settings,” or by enabling the Global Privacy Control. We do not share information we collect as part of providing advisory services to clients for these purposes.

7. Third-Party Vendors

Third parties that place cookies on the Website are identified in our Cookies Policy.

8. Gramm-Leach-Bliley Act and Client Information

As a financial institution, Latigo Peak is subject to Title V of the Gramm-Leach-Bliley Act (“GLBA”) and the SEC’s Regulation S-P, which govern how we collect, use, share, and safeguard “nonpublic personal information” about our consumers and clients. Nonpublic personal information may include information such as your Social Security number, income, account balances, transaction history, and investment experience that you provide to us or that we obtain in connection with providing financial services to you. Financial information you submit through the Website to seek our services, such as information about your assets or investment objectives, may be nonpublic personal information that we handle in accordance with our Client Privacy Notice.

We provide clients with our Client Privacy Notice at the start of the relationship and as required by law thereafter. The Client Privacy Notice explains:

• the types of nonpublic personal information we collect and share;
• the reasons we share that information, including for our everyday business purposes, for our own marketing, and with our affiliates;
• whether you can limit that sharing and how to do so; and
• how we protect that information.

We do not disclose nonpublic personal information about clients or former clients to nonaffiliated third parties except as permitted or required by law, such as to service providers that help us maintain your accounts, to custodians and broker-dealers that process your transactions, and to regulators. Our current Client Privacy Notice is available at https://www.latigopeak.com/client-privacy-notice/ or upon request by contacting us using the information in Section 2.

Certain state laws give clients additional rights regarding the sharing of their financial information. For example, accounts with a California or Vermont address may be treated as having opted out of certain information sharing unless the client consents. Those rights are described in our Client Privacy Notice.

9. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Policy, including to respond to your inquiry, maintain our relationship with you, and comply with our legal, regulatory, tax, accounting, and recordkeeping obligations. As a regulated investment adviser, we are required to preserve certain records, including certain written communications, for prescribed periods under the Investment Advisers Act of 1940 and the rules adopted under it, and we may be subject to additional retention requirements under other federal and state laws.

When determining how long to retain information, we consider the amount, nature, and sensitivity of the information; the purposes for which we process it; applicable legal and regulatory requirements; and whether the information is needed to establish, exercise, or defend legal claims. When personal information is no longer needed, we will delete, destroy, or de-identify it in accordance with our records retention policy and applicable law.

We retain contact form submissions and related correspondence for five years from the end of the fiscal year in which the record was created, consistent with Investment Advisers Act recordkeeping rules, unless a longer period is required. Analytics and advertising cookie data are retained for no longer than allowed by law. Inquiries that do not result in a client relationship are retained for periods allowed by applicable law unless subject to recordkeeping requirements.

10. How We Protect Personal Information

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, disclosure, and destruction. These safeguards include:

• Administrative safeguards, such as written information security policies, employee confidentiality obligations and training, access limited to personnel with a business need, and oversight of service providers.
• Technical safeguards, such as encryption of data in transit and at rest, multi-factor authentication, endpoint detection and response, continuous security monitoring, email security filtering, and regular software patching.
• Physical safeguards, such as secured offices and restricted access to facilities and equipment.

No method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security. Please do not send sensitive information, such as account numbers or Social Security numbers, through unencrypted email or Website forms. We maintain an incident response program as required by SEC Regulation S-P. If we learn of a security incident affecting your personal information, we will notify you as required by applicable law, including, where Regulation S-P applies, as soon as practicable and no later than 30 days after we become aware that sensitive customer information was, or is reasonably likely to have been, accessed or used without authorization.

11. Children’s Privacy

The Website is intended for adults and is not directed to children under 13 years of age. We do not knowingly collect personal information from children under 13 through the Website. If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will delete that information. If you believe a child under 13 has provided personal information to us, please contact us using the information in Section 2. We do not knowingly sell or share the personal information of consumers under 16 years of age.

12. Third-Party Links and Services

The Website may contain links to third-party websites, platforms, or services, such as social media sites, news sources, or research providers. These links are provided for convenience only. We do not control, and are not responsible for, the content, privacy practices, or security of third-party websites, and the inclusion of a link does not imply our endorsement. We encourage you to review the privacy policies of any third-party site you visit. Information you provide to a third party is governed by that party’s privacy policy, not this Policy.

13. Your Choices

• Marketing communications. You may opt out of marketing communications at any time by contacting us. We may still send you non-marketing messages, such as responses to your inquiries or service-related communications.
• Cookies and tracking technologies. You can manage cookies through your browser settings and through our cookie consent tool, CookieYes, by clicking “Cookie Settings” in the footer of any page or visiting our cookie preference center. Non-essential cookies, including advertising cookies, are set only with your consent. See our Cookies Policy at https://www.latigopeak.com/cookies-policy/ for more information.
• Opt-out preference signals. The Website recognizes the Global Privacy Control (“GPC”) and similar legally recognized opt-out preference signals. When we receive such a signal, we treat it as a request to opt out of the sale of personal information, sharing for cross-context behavioral advertising, and targeted advertising for the browser or device sending the signal, and we will not set advertising cookies or pixels on that browser or device. To learn more about GPC, visit https://globalprivacycontrol.org. See the Cookies Policy for how we respond to Do Not Track signals.
• Interest-based advertising. You may opt out of sharing for cross-context behavioral advertising by clicking the “Do Not Sell or Share My Personal Information” link in the Website footer or visiting Do Not Sell or Share My Personal Information. You can also opt out of interest-based advertising from participating companies at https://optout.aboutads.info and https://optout.networkadvertising.org. Opting out does not mean you will stop seeing ads, but the ads you see will be less tailored to you.

14. State Privacy Rights

Residents of certain states have rights under state consumer privacy laws regarding their personal information. This Section describes those rights and how to exercise them. These rights do not apply to personal information that is exempt under applicable law, including information collected, processed, or disclosed under the GLBA and its implementing regulations, which is instead governed by our Client Privacy Notice. Some state laws also exempt financial institutions subject to the GLBA entirely. Where a state law does not apply to us, we may nonetheless choose to honor requests consistent with this Section, at our discretion.

Certain state privacy laws apply to us only if we meet applicable thresholds, and some exempt GLBA financial institutions. Where a law does not apply, we may honor requests at our discretion.

14.1 California Residents

This Section supplements the rest of this Policy and applies to California residents under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (together, the “CCPA”).

Notice at Collection and Categories of Personal Information

The table below describes the categories of personal information we collect, or expect to collect, through the Website and our related communications, the sources of that information, the purposes for which we use it, and the categories of recipients to whom we disclose it for business purposes. We do not sell personal information for money. In the preceding 12 months, we have shared identifiers (such as IP address and online identifiers) and internet or other electronic network activity with advertising and social media partners for cross-context behavioral advertising. You may opt out through the “Do Not Sell or Share My Personal Information” link at Do Not Sell or Share My Personal Information or by enabling GPC. We will update this section at least once every 12 months. A link to this notice will be provided on or near each Website form at or before the point of collection.

Sensitive personal information. We do not intend to collect sensitive personal information through the Website. To the extent we collect sensitive personal information, we use and disclose it only for purposes permitted under the CCPA that do not give rise to a right to limit, and not to infer characteristics about you.

Retention. We retain each category of personal information for the period described in Section 9.

Your California Rights

Subject to certain exceptions, California residents have the following rights:

• Right to know. You may request that we disclose the categories of personal information we have collected about you; the categories of sources; our business or commercial purposes for collecting, selling, or sharing personal information; the categories of third parties to whom we disclose personal information; and the specific pieces of personal information we have collected about you.
• Right to delete. You may request that we delete personal information we collected from you, subject to exceptions, such as where we must retain information to comply with legal or regulatory obligations.
• Right to correct. You may request that we correct inaccurate personal information we maintain about you.
• Right to opt out of sale or sharing. You may opt out of the sale of your personal information or sharing for cross-context behavioral advertising. To opt out, click the “Do Not Sell or Share My Personal Information” link in the Website footer or visit Do Not Sell or Share My Personal Information, or enable GPC in your browser. We will process GPC signals as described in Section 13.
• Right to limit use of sensitive personal information. You may have the right to limit our use and disclosure of sensitive personal information to purposes permitted by the CCPA. As described above, we do not use or disclose sensitive personal information in a manner that triggers this right.
• Right to non-discrimination. We will not discriminate or retaliate against you for exercising any of your CCPA rights, such as by denying services, charging different prices, or providing a different level or quality of service.

How to Submit a Request

You or your authorized agent may submit a request by calling us toll-free at 833-452-8446 or emailing us at compliance@latigopeak.com. Requests to opt out of sale or sharing may also be submitted at Do Not Sell or Share My Personal Information. We will confirm receipt of your request within 10 business days and respond within 45 calendar days, which may be extended by an additional 45 days when reasonably necessary, with notice to you.

Verification. To protect your information, we will verify your identity before fulfilling a request to know, delete, or correct, by matching information you provide with information we maintain. The verification steps depend on the sensitivity of the information and the type of request. We do not require verification for requests to opt out of sale or sharing.

Authorized agents. You may designate an authorized agent to make a request on your behalf. We may require the agent to provide signed written permission from you and may require you to verify your identity directly with us, unless the agent holds a valid power of attorney under California Probate Code sections 4000 to 4465.

Shine the Light

California Civil Code section 1798.83 permits California residents who have an established business relationship with us to request information about the personal information we disclosed to third parties for their direct marketing purposes during the preceding calendar year. We do not disclose personal information to third parties for their own direct marketing purposes. To make a request, contact us using the information in Section 2 and include “Shine the Light Request” in the subject line.

14.2 Residents of Other States

Depending on your state of residence, you may have some or all of the following rights under applicable state privacy laws, including those of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Vermont, and Virginia, as those laws take effect and to the extent they apply to us:

• Access: to confirm whether we process your personal information and to access it.
• Correction: to correct inaccuracies in your personal information.
• Deletion: to delete personal information you provided or that we obtained about you.
• Portability: to obtain a copy of your personal information in a portable and, where technically feasible, readily usable format.
• Opt out: to opt out of the processing of your personal information for targeted advertising, the sale of personal information, or profiling in furtherance of decisions that produce legal or similarly significant effects. You may opt out of targeted advertising and sale through the “Do Not Sell or Share My Personal Information” link at Do Not Sell or Share My Personal Information or by enabling GPC.
• List of third parties: in certain states, to obtain a list of the specific third parties or categories of third parties to which we have disclosed personal information.
• Consent for sensitive data: to have your sensitive data processed only with your consent, where required.

To exercise these rights, contact us using the methods in Section 2. We will respond within the time required by applicable law, generally 45 days, which may be extended where permitted. If we decline to take action on your request, you may appeal our decision by emailing compliance@latigopeak.com with the subject line “Privacy Request Appeal” within a reasonable period after receiving our decision. We will respond to your appeal within the time required by law. If your appeal is denied, you may contact the attorney general of your state.

We will not discriminate against you for exercising your privacy rights. These rights are subject to the exemptions and limitations under applicable law, including the exemptions for financial institutions and for data subject to the GLBA.

15. Visitors Outside the United States

The Website is directed to U.S. residents, and we do not market through it outside the United States. If you access the Website from abroad, or are an existing client residing abroad, your information is transferred to and processed in the United States. Where the EU/UK GDPR applies, we rely on legitimate interests, contract, legal obligations, and consent for non-essential cookies, and you may have rights to access, rectify, erase, restrict, object, port, withdraw consent, and complain to your supervisory authority.

16. Updates to This Policy

We may update this Policy from time to time to reflect changes in our practices, the Website, or applicable law. When we do, we will post the revised Policy on the Website and update the “Last Updated” date above. If we make material changes, we will provide additional notice as required by law, such as a prominent notice on the Website or an email to you. Changes take effect when posted unless we state otherwise. We encourage you to review this Policy periodically. We will review and update this Policy at least once every 12 months.

17. Accessibility

We are committed to making this Policy accessible to individuals with disabilities. To request this Policy in an alternative format, please contact us using the information in Section 2.