Information we collect

• What you give us. Your email address, and anything you choose to include when you email us or reply to one of our messages, such as your name or a question.

• Submission details. The date and time you submitted a form.

• Information collected automatically. When you visit our website, our website platform and analytics tools collect standard technical information such as your IP address, browser and device type, the pages you view, and the site that referred you. Our sign-up forms use Google reCAPTCHA, which collects device and usage information to tell people apart from automated spam. When you open a guide link, the file-hosting service that delivers it may record the time and technical details of that request.

We will never ask you to send Social Security numbers, account numbers, passwords or other sensitive financial information by email, and we ask that you not send them that way.

How we use it

• To send you the guide or information you asked for.

• To follow up with you personally about it and about our services, and from time to time to send educational content, firm news or event invitations.

• To answer your replies and questions.

• To keep records of our communications, as securities and insurance regulations require.

• To protect our website and forms from spam, fraud and abuse.

• To understand, in aggregate, how our website is used so we can improve it.

How we share it

We do not sell, rent or trade your email address, and we do not share it with other companies for their own marketing. We share it only with:

• Service providers that host our website and forms (Squarespace), our email and document storage (Google Workspace), our internal work management (monday.com), guide delivery (Box), spam protection (Google reCAPTCHA) and compliance archiving. They may use it only to provide their services to us.

• Compliance and supervision. Emails exchanged with us are automatically archived and can be reviewed by authorized compliance personnel, including those of the firm through which our investment advisory services are offered.

• Regulators and legal authorities, when required by law, regulation, subpoena or regulatory examination, or when needed to protect the rights and safety of our clients, our firm or others.

• A successor firm, if our business is merged with or acquired by another firm, which would remain bound by this policy for the information it receives.

Unsubscribing

You can stop our marketing emails at any time. Reply "unsubscribe" to any email from us, email info@28tengroup.com, or call (610) 300-2810. We will honor your request promptly, and never later than 10 business days after we receive it. Afterward we keep your address only to make sure we don't email you again, and we will not sell or transfer it. If you are a client, you will still receive the emails needed to service your accounts.

Your rights

Wherever you live, you can ask us to tell you what personal information we hold about you, to correct it, or to delete it. We may need to confirm your identity first, and we will respond within 45 days. Some records, including archived emails, must be kept for a period set by securities regulations, generally at least five years. Where that applies, we keep them only for that purpose and still remove you from our mailing lists. We will not treat you differently for making a request.

How long we keep it

We keep your email address while you are on our mailing list or in contact with us. Archived communications are kept for as long as regulations require, generally at least five years, and are then deleted.

How we protect it

We limit access to the team members who need it, use password-protected business accounts and encrypted connections, and work only with established service providers. We are based in the United States, and this website is intended for people in the United States. No system is perfectly secure; if a security incident affects your information, we will notify you as the law requires.

Cookies, analytics and Do Not Track

Our website uses cookies and Google Analytics to understand how visitors use the site. Google may collect information about your online activity over time and across different websites. You can manage your cookie preferences with the "Manage Cookies" option in our cookie banner, and you can opt out of Google Analytics with Google's browser add-on at tools.google.com/dlpage/gaoptout. Our website does not currently respond to browser "Do Not Track" signals. We do not use tracking pixels to see whether you open our emails.

Children

Our website and emails are intended for adults. We do not knowingly collect personal information from children under 13. If you believe a child has given us information, contact us and we will delete it.

Email is not for transaction instructions

Please do not use email to place trades or authorize transactions. Requests, orders or instructions sent by email will not be accepted or processed.

Changes to this policy

If we change this policy, we will post the updated version on this page with a new effective date. If a change materially affects how we use your email address, we will tell you before it takes effect, by email or with a notice on our website.

Contact us

The 28Ten Group
1605 N. Cedar Crest Blvd., Suite 108
Allentown, PA 18104
(610) 300-2810
info@28tengroup.com