The Burney Company Privacy Policy

Effective date: April 15, 2026

SUMMARY: WHAT THIS POLICY COVERS

Your privacy matters to us. This Privacy Policy explains what personal information The Burney Company collects, why we collect it, how we protect it, and the limited circumstances in which we may share it. We do not sell your personal information. Federal and state laws govern how we handle your information, and this notice is designed to meet — and, where possible, exceed — those requirements.

Federal law requires investment advisers to tell you how we collect, share, and protect your personal information. Please read this notice carefully. Federal law gives you the right to limit certain sharing of your information, and this notice explains how those rights apply to you.

OUR COMMITMENT TO YOUR PRIVACY

Protecting our clients' privacy is paramount to The Burney Company and its Portfolio Managers ("PMs"). It is The Burney Company's policy that no private client financial information obtained by us is sold or made available to third parties, except as provided below:

We will not share nonpublic personal information about our clients with nonaffiliated third parties without prior client consent, except for specific purposes described below.

Defined Terms: For purposes of this Privacy Policy, "nonpublic personal information" means any personally identifiable financial information that is not publicly available. "Affiliated" companies mean companies related to The Burney Company through common ownership or control. "Non-affiliated third parties" means any company not affiliated with The Burney Company.

HOW WE COLLECT INFORMATION

In connection with providing investment advisory services, we collect the following categories

of personal information from the sources described below:

• Identifiers: Name, postal address, phone number, email address, Social Security number or Tax ID;

• Financial Information: Account balances, investment positions, transaction history, income, and personal tax returns;

• Employment Information: Employer name, occupation, and related details; and

• Other Information You Provide: Investment experience, risk tolerance, and credit references.

We collect this information from:

• Client agreements and other information you provide to us directly, whether in writing, in person, by telephone, or electronically;

• Tax and financial documents you provide;

• Transactions conducted on your behalf, including account balances, positions, and investment history; and

• Public sources.

How Long We Keep Your Information: We retain your personal information for as long as necessary to provide services to you and to comply with our legal and regulatory obligations — generally at least five years after your advisory relationship ends, in accordance with SEC recordkeeping requirements. After that period, we securely destroy the information.

Cookies and Other Information Collected by Automated Means

We, our service providers, and our business partners may automatically log information about you, your computer, and activity on or through our websites and other channels. Automatically collected information may include your computer type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before coming to our website, general location information such as city, state, or geographic area, and information about your use and actions, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and the length of access.

Our service providers and business partners may collect this type of information over time and across third-party websites. On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies.

Information We Obtain From Social Media Platforms

We may maintain pages for our Company on social media platforms, including LinkedIn, Twitter, Google, YouTube, Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will govern your interactions and the provider’s collection, use, and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat that information in accordance with this Privacy Policy.

Information We Obtain From Other Third Parties

We may receive personal information about you from third-party sources, including marketing partners, publicly available sources, and data providers. Our agreements with those business partners restrict our use of any information obtained from our business customers.

HOW WE USE PERSONAL INFORMATION

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection.

To provide wealth management and investment management services, including support and maintenance. We communicate with you about these services, including through correspondence, emails, updates, and web announcements.

To comply with the law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety, we may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the terms and conditions governing the Privacy Policy; and (c) protect, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity.

With your consent. In some cases, we may specifically ask for your consent to collect, use, or share your personal information, such as when required by law.

We do not disclose clients' nonpublic personal information to other companies that may want to sell their products or services to you. We do not sell your personal information. For example, we do not sell client lists.

SHARING YOUR PERSONAL INFORMATION

We do not share your personal information with non- affiliated third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

Affiliated Companies. We may share your personal information with our affiliates and other related companies. Affiliated companies will only use the information as described in this Privacy Policy.

Service providers. We may share your personal information with third-party companies and individuals that provide services on our behalf or help us operate our business (such as customer support, hosting, analytics, call or message routing, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign.

We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including, but not limited to, platform providers, phone companies, and other vendors who assist us in delivering text messages.

Partners. We may sometimes share your personal information with partners or enable partners to collect information directly consistent with this Policy.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, at your direction, when necessary in the course of providing professional services to you.

For compliance, fraud prevention, and safety. We may share your personal information for compliance, fraud prevention, and safety purposes described above.

YOUR PRIVACY CHOICES

In this section, we describe the rights and choices available to all users.

Access or Update Your Information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging in.

Text message communications. We use text messaging solely to verify your identity. You will only receive a text message once per verification request when a verification event is initiated by you or on your behalf. The Company will not send unsolicited messages. Standard messaging rates apply, and message frequency may vary. Mobile carriers are not liable for delayed or undelivered messages. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Opt-out of text message communications. You may opt out of text messaging at any time by replying to any message with STOP, or by contacting us at CSA@burney.com. This will end the communications from that phone number. You may continue to receive service-related and other non-marketing text messages from other phone numbers managed by Company, and you may opt out of those in a similar fashion.

Opt-out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at CSA@burney.com. You may continue to receive service-related and other non-marketing emails.

Cookies. Most browser settings let you delete and reject cookies set by websites. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, you may not be able to use all the site's features, and the site may not function properly.

For more information about cookies, including how to view which cookies have been set in your browser and how to manage and delete them, visit https://www.allaboutcookies.org.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the service by designating it as required at the time of collection or through other appropriate means. Please note that declining certain disclosures may require termination of your advisory agreement and the transfer of your account.

CHANGES TO THE PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting the updated version on our website https://burneywealth.com/privacy-policy. We may, and if required by law, will also provide notification of changes in another way we believe is reasonably likely to reach you, such as via e-mail (if you have an account with your contact information on file) or another manner.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the website (or as otherwise indicated at the time of posting).

ADDITIONAL RIGHTS FOR CALIFORNIA RESIDENTS

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with additional rights regarding your personal information:

• Right to Know: You may request information about the categories and specific pieces of personal information we have collected about you.

• Right to Delete: You may request deletion of your personal information, subject to certain exceptions required by law or necessary to complete our services.

• Right to Correct: You may request correction of inaccurate personal information we hold about you.

• Right to Opt-Out of Sale or Sharing: We do not sell or share your personal information for cross-context behavioral advertising.

• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

To submit a rights request, please get in touch with us at [CSA@burney.com]. We will respond within 45 days as required by law.

OUR SECURITY PRACTICES AND INFORMATION ACCURACY

The Burney Company maintains a written information security program designed to protect your personal information. The Burney Company is committed to protecting the privacy of our clients. Our compliance procedures address these obligations, and all PMs and staff are required to comply with this policy.

Our safeguards include:

• Access Controls: Access to client information is restricted to employees and authorized agents with a legitimate business need;

• Electronic Security: Encrypted storage and transmission of sensitive data;

• Physical Security: Secured facilities and document handling procedures;

• Vendor Oversight: Due diligence on third-party service providers who handle client data; and

• Employee Training: Regular training on privacy and information security obligations.

We have internal controls to keep your information as accurate and complete as possible. Please get in touch with us if you believe any information we hold about you is inaccurate.

DATA SECURITY INCIDENTS

In the event of a data security incident affecting your personal information, The Burney Company will promptly notify affected clients in accordance with applicable federal and state law, including SEC Regulation S-P. Notifications will describe the nature of the incident, the information involved, the steps we have taken to address it, and recommended actions you can take to protect yourself.

QUESTIONS OR CONCERNS

If you have questions about this Privacy Policy, wish to access or correct your personal information, or believe your information may have been compromised, please call or email us at:

Phone: 866-928-7639

Email: CSA@Burney.com