“ALM First” is a brand name for a financial services business conducted by ALM First Group, LLC (“ALM First”) through its wholly owned subsidiaries: ALM First Financial Advisors, LLC; ALM First Advisors, LLC; ALM First Analytics, LLC; and ALM First Executive Benefits, LLC.
ALM First considers client information and data confidential. Our clients’ privacy is important to us. This Website Privacy Policy (the “Policy”) explains how we collect, use, disclose (“process”), and protect personal information when you visit our website at [company website] (the “Site”), and the rights you may have under applicable privacy laws.
1. Scope of This Policy
This Policy applies only to personal information collected through this Site. It does not apply to personal information ALM First Financial Advisors collects or processes through other means to provide investment advisory services; that information is covered by a separate privacy notice provided at or before the point of collection.
The Site may include links to unaffiliated third-party websites. We are not responsible for the content or privacy practices of those third parties.
2. Categories and Sources of Personal Information We Collect
We may collect the following categories of personal information:
Identifiers – Name, mailing address, email address, telephone number, and similar contact details.
Internet and Network Activity – IP address, browser type, operating system, device identifiers, engagement behavior (e.g., links clicked, forms completed).
We collect this information from:
- Information you provide directly via the Site or your communications with us.
- Information automatically collected through cookies and similar technologies.
3. Purposes and Lawful Bases for Processing (GDPR/UK GDPR)
Under the GDPR, we must identify a lawful basis for processing personal data. ALM First processes personal data for the following purposes and bases:
- To provide and improve our Site – based on our legitimate interests in operating and improving our online presence.
- To respond to inquiries or requests – where processing is necessary to perform a contract or take steps before entering one.
- To comply with legal obligations – such as responding to lawful requests from regulators or law enforcement.
- With consent – where required for optional cookies, marketing communications, or other specified purposes.
You may withdraw consent at any time by contacting us at privacy@almfirst.com.
4. Categories of Entities to Whom We Disclose Personal Information
We may disclose the above categories of personal information to:
- Service providers that host, maintain, or analyze Site traffic and support functionality.
- Regulatory authorities or law enforcement, as required by applicable law or regulation.
ALM First does not sell or “share” your personal information as defined under the CCPA or TDPSA.
5. Security
We employ administrative, technical, and physical safeguards designed to protect your personal information against unauthorized access, use, or disclosure. These include employee training, restricted access, authentication protocols, encryption (SSL), antivirus protection, and regular system monitoring.
6. Data Retention
We retain personal information for as long as necessary to fulfill the purposes described in this Policy, to comply with legal obligations, resolve disputes, and enforce our agreements. Retention periods vary depending on the type and purpose of data.
We continue to maintain the confidentiality and security of former clients’ personal information to the same extent as that of current clients. Personal information collected through the Site (such as website analytics data or contact form submissions) is retained only for as long as needed to operate, secure, and improve the Site or fulfill the purpose for which the information was provided, unless a longer retention period is required by law.
7. Cookies and Analytics
We use cookies and similar technologies to improve your experience, authenticate users, and analyze Site performance.
We use Google Analytics to help us understand how users interact with our Site. For more information about Google’s data practices, visit: https://www.google.com/policies/privacy/partners/
You may disable cookies in your browser, though some features of the Site may not function properly.
8. International Data Transfers (GDPR/UK GDPR)
If you are located in the European Economic Area (EEA) or United Kingdom, your personal data may be transferred to the United States or other jurisdictions that may not provide the same level of data protection. Where required, we implement safeguards such as Standard Contractual Clauses (SCCs) or rely on other lawful transfer mechanisms.
9. Your Privacy Rights
(a) Rights Under the GDPR/UK GDPR
If you are located in the EEA or UK, you have the following rights (subject to legal limits):
- Access – Request a copy of your personal data we hold.
- Rectification – Request correction of inaccurate or incomplete data.
- Erasure (“Right to be Forgotten”) – Request deletion of your data.
- Restriction – Request limitation of data processing.
- Portability – Request your data in a structured, machine-readable format.
- Objection – Object to processing based on legitimate interests.
- Withdrawal of Consent – Where processing is based on consent.
To exercise these rights, contact us at privacy@almfirst.com. You may also lodge a complaint with your local data protection authority.
(b) Rights Under the CCPA (California Residents)
Subject to applicable exceptions, California residents have the right to:
- Know what personal information we collect, use, disclose, and retain.
- Delete personal information we hold about you.
- Correct inaccurate personal information.
- Opt out of sale or sharing of personal information (we do not sell or share).
- Non-discrimination for exercising these rights.
To exercise your rights, contact:
Email: privacy@almfirst.com
Phone: 1-800-752-4628, extension 9
Verification and authorized agent procedures apply as described above.
(c) Rights Under the TDPSA (Texas Residents)
Texas residents have the right to:
- Confirm whether we are processing their personal data and access it.
- Correct inaccuracies in their personal data.
- Delete personal data provided by or obtained about them.
- Opt out of processing for targeted advertising or profiling (not applicable as we do not engage in such processing).
Requests may be submitted to privacy@almfirst.com. We will respond within 45 days as required by law.
10. Children’s Information
This Site is not directed to children under 16 years old, and we do not knowingly collect personal information from them. If we learn that we have inadvertently collected such information, we will delete it.
11. Changes to This Privacy Policy
We may update this Policy from time to time. Updates will be posted on this page with a revised “Effective Date.” Material changes will be communicated as required by law.
12. Contact Us
If you have questions about this Policy, or wish to exercise your privacy rights, please contact us:
Email: privacy@almfirst.com
Address: ALM First Group, LLC, 3800 Maple Ave, Suite 600, Dallas, Texas 75219
Telephone: 1-800-752-4628, extension 9
If you are located in the EU/UK, you may contact our Data Protection Officer (if applicable) at the same email address.
Effective Date: November 29, 2023
Last Updated: December 18, 2025
