Fisher\SMB™ Privacy & Cookie Policy

(In effect as of June 2025) 

General

Fisher\SMB is committed to respecting the privacy of consumers and its customers, including visitors to our U.S. websites. This Privacy & Cookie Policy sets out how we collect, use, and share personal information. This Privacy & Cookie Policy also explains how we use cookies and similar technologies on our U.S. websites and subsites. You can also access this Privacy & Cookie Policy via our homepage and from the bottom of every page by clicking on the appropriate link in the footer. 

Fisher\SMB is registered with the U.S. Securities and Exchange Commission (the “SEC”) as an investment adviser and is required to comply with SEC Regulation S-P (“Reg. S-P”), as well as the U.S. Gramm-Leach-Bliley Act of 1999 (the “GLB Act”). Reg. S-P and the GLB Act require Fisher\SMB to have policies and procedures in place to protect the security and confidentiality of the non-public personal information of consumers and customers, and to provide a privacy notice to such persons describing our privacy policies and procedures. Use of the Fisher\SMB website constitutes acceptance of this Privacy Policy. The continued use of the Fisher\SMB website following the posting of changes constitutes your acceptance of such changes. 

What information Fisher\SMB™ collects

For purposes of this Privacy Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. Personal Information does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified or aggregated; or information covered by certain sector-specific privacy laws, as consistent with state law. Fisher\SMB collects the following information: 


• Fisher\SMB collects information from business contacts who request informational materials, including name, business name, address, telephone number, and email address.
  • Fisher\SMB may record and/or monitor phone calls and electronic communications for quality assurance and training purposes.
  • Fisher\SMB collects information provided orally and in writing via email, mail, online or in person from prospective business clients and clients.
  • Our Sites use cookies and other online tracking technologies to collect and share technical information, such as data reflecting IP address, browser used to view the Site, operating system, resolution of screen, location, language settings in browser, the site directing to our Site, keywords searched, clickstream data, the number of page views, inferences drawn from any personal information etc. Please see “Cookie Policy” below.

How Fisher\SMB™ uses information collected

Fisher\SMB may use personal information for the following reasons: 

• Internal record keeping.
• To improve products and services.
• For quality assurance and training purposes.
• To follow up, either by email, phone or mail, with businesses who have requested information and/or materials.
• To periodically send promotional email or mail about services, recent developments, or other information businesses may find interesting using the email address or mailing address provided when requesting information.
• To optimize and personalize marketing.
• To access certain special features or areas of our Sites.
• To analyze the financial situation of prospective clients and to provide investment advisory and management services to clients.
• As otherwise permitted by law.

To Whom Fisher\SMB™ discloses Personal Information

Fisher\SMB discloses information to the following individuals or entities:

• Our affiliates. We may share personal information with our affiliates, in which case, we will require such affiliates to comply with the terms of this Privacy Policy.
• Service providers. We share personal information with our service providers to provide services on our behalf, such as analytics, advertising, hosting, marketing, customer and technical support, and other services.
• Third-party platform advertising. We may share your information with third-party platform providers who assist us in serving advertising regarding the Sites and Services to others who may be interested.
• Compliance and harm prevention. Under certain circumstances, we may share personal information as we believe necessary to comply with applicable law, rules and regulations; to enforce our contractual rights; to investigate possible wrongdoing in connection with the Site and Services; to protect and defend the rights, privacy, safety and property of Company, you or others; and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities.
• Successor companies or combined entities. If we or our subsidiaries are involved in a merger, acquisition, asset sale, or other corporate combination, your personal information may be transferred to the acquiring or surviving entity.

How to contact Fisher\SMB™

If you have any questions or concerns regarding this Privacy & Cookie Policy, Fisher\SMB can be contacted as follows:

Fisher\SMB
6404 International Pkwy, Ste 1100
Plano, TX 75093
USA

Please ensure that full contact name, business name and address are provided in exactly the form in which it was originally provided to Fisher\SMB to avoid any possible confusion with a different company.
To unsubscribe from Fisher\SMB’s email communications, send an email to optout@frs.net. Please put “UNSUBSCRIBE” in the subject field and include the email address where you received the content, along with any additional email addresses you would like suppressed. We will do our best to prevent you from receiving our email content in the future.

Security

In order to prevent unauthorized access or disclosure, Fisher\SMB has put in place suitable physical, electronic and managerial procedures to safeguard and secure information. Nevertheless, due to the nature of the Internet and Internet technologies, security and privacy risks cannot be eliminated and Fisher\SMB cannot guarantee that information will not be disclosed in ways not otherwise described in this privacy policy.

Retention

We will retain your personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Other Websites

Our Sites may contain links to enable users to visit other websites of interest easily. However, once users have used these links to leave our Sites, users should note that Fisher\SMB does not have any control over that other website. Therefore, Fisher\SMB cannot be responsible for the protection and privacy of any information which users provide while visiting other sites, and such sites are not governed by this Privacy & Cookie Policy. Businesses should exercise caution and look at the privacy and cookie policies applicable to the website in question.

Cookie Policy

A cookie is a small text file downloaded to an individual’s computer (or other device) when accessing webpages that use them. Cookies and other online tracking technologies, such as pixels, tags, or web beacons (collectively referred to in this policy as “cookies”) allow a website to store and retrieve information about visitors’ online activity. Cookies are, for example, how a website remembers what display language you chose or what items you put into your online shopping cart.

• Cookies can be categorized by who places them:
  • First-party cookies: These cookies are downloaded to an individual’s computer from a server or domain managed by the publisher of the website whose service the individual is requesting.
  • Third-party cookies: These cookies are downloaded to a computer from a server or domain that is not managed by the publisher, but by another entity that may be seeking data obtained through cookies.
    
    Cookies can also be categorized by their duration:
  • Session cookies: These cookies are designed to collect and store data while the individual accesses a web page. They are often used to store information for the duration of a visit to the site (e.g., what account you are logged into). Once an individual leaves the website, the session cookie is deleted.
  • Persistent cookies: These cookies store data on a computer for the duration of the period set within the cookie’s file, which is determined by the entity controlling the cookie, and can range from a few minutes to several years, or until manually deleted.

Lastly, cookies can be categorized by the function they serve. Fisher\SMB uses the following types of first- and third-party cookies:

1. Functionality Cookies 

These cookies allow the website to remember choices you make (such as your geographic region or preferred text size). Functionality cookies do not collect any personal information. Enabling functionality cookies may be necessary to access the full content of website material.

2. Personalization Cookies 

Personalization cookies allow a website to remember information that changes the page’s appearance or behavior, such as, for example, the language selected for viewing the page. 

3. Analytics Cookies

Analytics cookies collect pseudonymized information to analyze how individuals browse a website and enable Fisher\SMB to measure the number of visitors to its websites, as well as to measure and analyze how individuals interact with the site. We use this information to improve the websites and the products or services offered.

4. Behavioral Advertising Cookies

Fisher\SMB serves advertisements on various websites using third party companies. If an individual visits a website or clicks on one of Fisher\SMB’s advertisements, behavioral cookies will be placed on the individual’s computer. Behavioral cookies allow Fisher\SMB to manage and optimize its digital marketing (e.g., banner ads, pages offering informational brochures, email campaigns, etc.). Behavioral cookies may be used to build a profile to provide content more relevant to an individual’s interests. They adapt advertising and the content the individual sees on other websites based on browsing habits, including how the individual navigates websites, as well as how the individual interacts with internet advertising.

“Do Not Track” Signals

Some internet browsers send signals to each website visited, giving notice of the user’s privacy preferences. Our Sites recognize signals sent through “Global Privacy Control” and will honor requests to limit information sharing. You can find tools to implement a Global Privacy Control at https://globalprivacycontrol.org/#download. Please keep in mind that Global Privacy Control signals are limited to the device and browser. Users should enable Global Privacy Control on each device and browser. If users block or clear cookies, they may need to re-enable Global Privacy Control.

How to Manage Cookies

To learn more about behavioral advertising cookies and to opt in or out of multiple advertising networks at once, you can visit the website YourAdChoices. Some advertising networks do not participate in the YourAdChoices service. To opt out of some of these networks, please visit the consumer opt-out page of the Network Advertising Initiative.

As explained above, cookies help you to get the most out of the websites that make use of this technology. Disabling cookies may affect the functionality of many of the websites you visit. If you do disable cookies, performance and functionality will be affected.
If you wish to delete, disable, or re-enable cookies, you may do so through your browser as follows: 

• Microsoft Edge: https://support.microsoft.com/en-us/windows/manage-cookies-in-microsoft-edge-view-allow-block-delete-and-use-168dab11-0753-043d-7c16-ede5947fc64d
• Chrome: https://support.google.com/chrome/answer/95647?hl=en 
• Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer 
• Safari: http://www.apple.com/au/support/mac-apps/safari/ 
• All other browsers: Please look for a ‘help’ function in the browser or contact the browser provider. 

Changes to Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Sites, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy. We recommend that you review this page periodically as these policies are subject to change.

California Privacy Notice

This Section of the Privacy Policy applies to any business contacts who are California residents about whom we collect personal information. The provisions contained within this section are intended to provide notice in compliance with the California Consumer Privacy Act of 2018 (“CCPA”). Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy.
The CCPA provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of personal information, as well as rights to access, delete, and restrict the sale of certain personal information we collect about them. California residents also have the right not to receive discriminatory treatment by us for the exercise of your privacy rights under the CCPA.

Collection of Personal Information

• Fisher\SMB may have or has collected the following categories of personal information in the last twelve (12) months:  
  • Identifiers, including your first and last name; mailing address; email address; phone number; online identifiers as detailed below including IP address or device IDs; and/or other similar identifiers.
  • Financial or customer information (see Cal. Civil Code § 1798.80(e)), including your personal credit or debit card number and related payment card information; personal bank account and routing number; and/or other financial information.
  • Commercial information, which includes our Services that you have purchased, obtained, or considered; and/or other purchasing or consumer histories, tendencies, and preferences.
  • Employment information, which includes employer and employment history.
  • Information relating to Internet activity or other electronic network activity, which includes the information disclosed in Section 1(B) of our Privacy Policy.
  • Geolocation data, which includes Global Positioning System (“GPS”) data based on your IP address.
  • Audio, electronic, visual, or similar information, which may include photographs, videos, or audio recordings, as well as any other related content that you choose to submit to us.
  • Information related to characteristics protected under California or federal law, which may include age and/or date of birth; gender or gender identity; race or ethnicity; religion; sexual orientation; marital status; national origin; and/or disabilities.
  • Inferences, based on the above information.

Sensitive personal information. Certain types of personal information that we collect, as described above, may constitute “sensitive personal information” under California law, including

• Precise geolocation data
• Account log-in in combination with required credentials
• Social Security number, driver’s license, state identification card, or passport number
• Precise geolocation
• Racial and/or ethnic origin
• Trade union membership
• Gender or gender identity

Sources of Personal Information

Fisher\SMB obtains information used for marketing purposes directly from businesses who request informational materials, through cookies and other online tracking technologies, from existing clients and other referral sources, and from list vendors that gather and sell identifying information. Employment-related information is obtained from third party recruiters, employee referrals, directly from individuals, and background check providers. Information relating to non-financial services is obtained directly from individuals.

Use of Personal Information

We may use personal information for the following purposes:

• Internal record keeping.
• To improve products and services.
• For quality assurance and training purposes.
• To follow up, either by email, phone or mail, with businesses who have requested information and/or materials.
• To periodically send promotional email or mail about services, recent developments, or other information businesses may find interesting using the email address or mailing address provided when requesting information.
• To optimize and customize marketing.
• To access certain special features or areas of our Sites
• To analyze the financial situation of prospective clients and to provide investment products and management services to business clients.
• As otherwise permitted by law.

Disclosure of Personal Information

Fisher\SMB discloses business information to service providers for the business purposes identified above. Fisher\SMB discloses personal information to regulatory agencies, law enforcement authorities, and other third parties when required or authorized by law. Fisher\SMB discloses email addresses and electronic network activity information to certain advertising and analytics partners, including social media platforms. These third parties use the information to show you ads targeted to your interests. This type of disclosure is defined as “selling” or “sharing” in California law. You may opt out of this disclosure by emailing optout@frs.net. As described above under “Do Not Track Signals,” enabling the Global Privacy Control setting in your browser is another way to limit disclosure.

• Over the last twelve (12) months we have sold/shared the following categories of personal information:
  • Identifiers
  • Commercial information
  • Internet or other electronic network activity information
  • Audio, electronic, visual, or similar information
  • Inferences

Fisher\SMB uses business information only for the purposes allowed by California law.
Fisher\SMB does not knowingly “sell” or “share” the personal information of California residents under 16 years of age, as those terms are defined in California law.

Retention

Fisher\SMB retains business information for internal use in accordance with applicable law and for as long as it is needed to establish, exercise, or defend any legal claims.

Notice of Right to Opt Out of Sale/Sharing

We “sell”/”share” personal information, as those terms are defined under California law, to the extent we disclose personal information to third parties for purposes of cross-context behavioral advertising, as defined under California law. We may also “sell”/”share” personal information, including your first and last name, email address, mailing address, phone number, date of birth, and geolocation, with third parties, such as our licensees, distributors, partners and others with whom we have marketing or other relationships, for the third parties’ direct marketing purposes.
To opt out of our “sale”/”sharing” of personal information, please follow the instructions in the section below.

Your Privacy Rights 

California residents may exercise the following rights in relation the personal information that Fisher\SMB holds about them. California residents have the right to: 

• request disclosure of the categories of personal information collected, specific pieces of personal information collected, categories of sources, purposes for collecting and using, and categories of third parties to whom the information is disclosed, “sold” or “shared,” as those terms are defined in California law.
• request deletion of their personal information.
• request correction of inaccurate personal information.
• not be discriminated against for exercising their rights with respect to personal information.
• request to opt out of the sale/sharing of your personal information

To exercise these rights, California residents or their authorized agents should contact us via mail to:
Fisher\SMB
6404 International Parkway, Suite 1100
Plano, Texas 75093
Requests must include sufficient information to verify the requester’s identity, including name, email, phone, and zip code. Deletion and correction requests will require additional confirmation. For requests submitted by agents, proof of authority, such as a copy of a valid power of attorney, will generally be required. Fisher\SMB will confirm receipt of a request within 10 days and respond within 45 days.

Notice to Nevada Residents

We do not “sell” personal information as that term is defined under Nevada law, but Nevada residents have the right to request to opt out of any future sale of their personal data under Nevada SB 220. If you are a Nevada resident and would like to make such a request, please contact us, as described above. Please include your full name, email address, and postal address in your email or mail request so that we can verify your Nevada residence and respond. In the event we sell your personal information after the receipt of your request, we will make reasonable efforts to comply with such request.