Privacy Policy

Information Privacy Policy

Version: 2.0
Implementation Date: July 24, 2026

Summary of Policy Topic

This Privacy Policy describes how “Richey May” branded entities collect, use, maintain, disclose, and protect personal information collected through their websites, branded microsites, online forms, event registration pages, marketing activities, client intake processes, business development activities, and other online or offline interactions where this Privacy Policy is posted or referenced. This Privacy Policy applies to the information practices described here unless a separate privacy notice, engagement letter, client agreement, confidentiality obligation, or other specific notice applies. Where a separate notice or agreement applies, it will govern to the extent of any conflict. Information received or processed on behalf of a client may be governed by the applicable client agreement and the client’s instructions.

For purposes of this Privacy Policy, “Richey May” refers collectively to Richey, May & Co., LLP, RM Advisory LLC, their affiliated and subsidiary entities (“we” or “us”). The applicable Richey May entity responsible for your personal information may depend on the website, service, event, business relationship, or interaction involved. If you are unsure which Richey May entity is responsible for your information, contact privacy@richeymay.com and provide the Site, service, event, or interaction involved.

“Site” means any Richey May branded website, branded microsite, interactive feature, widget, plug-in, application, content, download, form, event page, or other electronic service maintained by or on behalf of Richey May or an affiliated entity, unless a separate privacy notice applies.

“You” and “your” mean you as an individual and, if you are acting on behalf of another person or entity, that person or entity.

Please review the Terms of Use posted on the applicable Site. By using the Site, you acknowledge that you have received this Privacy Policy. Your use of the Site remains subject to the applicable Terms of Use. Where consent is required by law, we will request consent separately through an appropriate mechanism. You may choose not to provide personal information, although doing so may limit your ability to use certain features or receive certain services.

This Privacy Policy does not apply to the privacy practices of unaffiliated third parties, including social media platforms, advertising networks, external websites, or services that may link to or interact with the Site. We encourage you to review the privacy policies of those third parties to understand their practices.

PERSONAL INFORMATION WE COLLECT

We may collect personal information from individuals in a variety of ways, including when individuals visit the Site, register for or attend events, subscribe to newsletters, respond to a survey, complete a form, request information, communicate with us, engage us for services, or otherwise interact with us.

Depending on the interaction, personal information may include name, business contact information, email address, mailing address, phone number, company name, job title, account or billing information, event registration details, marketing preferences, communications with us, and other information you voluntarily provide.

Certain professional services may involve access to nonpublic personal information, confidential client information, or regulated information. In those situations, we process information consistent with applicable professional obligations, contractual obligations, client instructions, and applicable law.

You may choose not to provide certain information; however, doing so may prevent us from responding to your request, providing certain services, processing a transaction, registering you for an event, or enabling certain Site features.

NON-PERSONAL IDENTIFICATION INFORMATION AND USAGE INFORMATION

We may collect non-personal or usage information when individuals interact with the Site, including browser type, device type, operating system, internet service provider, IP address, referring and exit pages, pages viewed, dates and times of visits, links clicked, approximate location derived from IP address, and similar technical or usage information.

COOKIES AND TRACKING TECHNOLOGIES

Depending on the Site and its configuration, we may use, cookies, pixels, tags, analytics tools, embedded scripts, local storage, log files, and similar technologies to operate the Site, improve performance, understand Site usage, measure interactions, support security, personalize user experience, manage marketing activities, and deliver or measure advertising where applicable.

Some cookies are necessary for the Site to function. Other cookies and tracking technologies may support analytics, performance, functionality, advertising, or marketing. Site statistics may be compiled by or reported through analytics providers or other service providers.

Where required by law, users will be provided a meaningful opportunity to accept, reject, or manage non-essential cookies and similar tracking technologies. If we use advertising, remarketing, pixels, or technologies that constitute “sale,” “sharing,” or targeted advertising under applicable law, we will provide an appropriate opt-out mechanism, such as a “Do Not Sell or Share My Personal Information” link or privacy preference center.

We may maintain a separate Cookie Notice or Privacy Center that provides additional information about cookie categories, the purposes of each category, third-party technologies, retention periods where practical, and available preference controls. Browser-level controls may also allow you to refuse or delete cookies, although some parts of the Site may not function properly if cookies are disabled.

HOW WE USE COLLECTED INFORMATION

We may use personal information and other information we collect for the following purposes:

To provide, operate, maintain, improve, and promote our Sites, services, events, and business activities.

To respond to inquiries, comments, questions, requests, and customer service or support needs.

To process transactions, manage accounts, send confirmations, invoices, administrative messages, technical notices, security alerts, and support communications.

To deliver professional services, manage client relationships, conduct intake, support engagements, and satisfy contractual obligations.

To send newsletters, event information, updates, offers, surveys, promotions, or other marketing communications, subject to applicable opt-out rights.

To personalize user experience and understand how users interact with the Site, our communications, and our services.

To administer surveys, promotions, events, webinars, or other features.

To protect the security, integrity, and availability of our systems, data, Site, clients, employees, and business operations.

To detect, investigate, prevent, or respond to suspected fraud, security incidents, illegal activity, policy violations, or misuse of the Site.

To comply with legal, regulatory, contractual, accounting, audit, tax, professional, and risk management obligations.

To evaluate or carry out business transactions, integrations, acquisitions, reorganizations, or other corporate activities, subject to appropriate safeguards.

You may opt out of marketing communications by following the unsubscribe instructions included in the communication or by contacting privacy@richeymay.com. We may continue to send non-marketing communications where permitted by law, including service, security, transactional, or administrative messages.

AFFILIATE AND SUBSIDIARY SHARING

We may share personal information among Richey May entities, affiliates, subsidiaries, branded business units, and internal teams for legitimate business purposes, including providing and improving services, responding to inquiries, managing client relationships, conducting marketing and event activities, administering websites and systems, maintaining security, satisfying compliance obligations, supporting business operations, and evaluating or integrating business opportunities.

Where a Richey May entity receives personal information from another Richey May entity, it will process that information consistent with this Privacy Policy, applicable law, contractual obligations, professional obligations, and any more specific notice provided at the point of collection.

HOW WE PROTECT YOUR INFORMATION

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, alteration, disclosure, destruction, or misuse. These safeguards may include access controls, encryption, logging, monitoring, secure configuration, vulnerability management, employee training, vendor risk management, incident response processes, and data protection policies.

No method of transmission or storage is completely secure. We cannot guarantee absolute security, but we work to protect personal information using reasonable safeguards appropriate to the nature of the information and our business operations.

To report a suspected privacy incident, security incident, unauthorized disclosure, or other concern about personal information, contact privacy@richeymay.com and include the nature of the concern, the affected Site or service, and your contact information. We will route the matter to the appropriate privacy, security, legal, or operational personnel.

RETENTION

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, provide services, manage relationships, comply with legal, regulatory, contractual, accounting, audit, tax, and professional obligations, resolve disputes, enforce agreements, maintain security, and conduct legitimate business operations.

Retention periods vary based on the nature of the information, the purpose for which it was collected, applicable legal or professional requirements, contractual requirements, and operational needs. We may retain certain professional service records, client records, security logs, marketing records, event records, privacy request records, vendor records, and business records for different periods depending on the applicable requirements.

SOURCES OF PERSONAL INFORMATION

We may collect personal information from the following sources:

Directly from you, including through forms, email, telephone, meetings, events, registrations, service requests, and other interactions.

From your organization or representatives where you interact with us in a business or professional capacity.

From affiliates, subsidiaries, service providers, vendors, business partners, or professional advisors.

From clients or third parties where necessary to provide professional services or as authorized by contract or law.

From Site usage, cookies, analytics tools, advertising technologies, and similar technologies.

From publicly available sources, professional directories, social media, and other lawful sources.

DISCLOSURE TO SERVICE PROVIDERS, CONTRACTORS AND THIRD PARTIES

We may disclose personal information to employees, contractors, service providers, professional advisors, vendors, affiliates, subsidiaries, and other parties who need the information to assist us in providing services, operating the Site, conducting business, supporting security, administering marketing or events, processing transactions, or satisfying legal and professional obligations.

Service providers and contractors are expected to process personal information only for permitted purposes and to maintain appropriate confidentiality, privacy, and security protections. Where required by law or contract, we enter into agreements designed to restrict the use, disclosure, retention, and processing of personal information.

We may disclose personal information if required to do so by law, regulation, subpoena, court order, legal process, government request, law enforcement request, professional obligation, or to establish, exercise, or defend legal claims. We may also disclose information where we believe disclosure is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, security incidents, threats to safety, violations of agreements or policies, or as otherwise permitted by law.

We may disclose or transfer information as part of a merger, acquisition, financing, reorganization, sale of assets, integration, or similar business transaction, subject to appropriate safeguards and applicable law.

PARENTS AND CHILDREN

The Site is intended for business and professional audiences and is not directed to children. We do not knowingly collect personal information online from children under the age of 13. If we learn that we have collected personal information from a child under 13 without appropriate consent, we will take reasonable steps to delete that information. Parents or guardians may contact us at privacy@richeymay.com regarding child privacy questions.

YOUR PRIVACY CHOICES AND REQUESTS

Depending on where you reside and how you interact with us, you may have rights to request access to personal information, correction of inaccurate personal information, deletion of personal information, portability of personal information, restriction or objection to certain processing, withdrawal of consent where processing is based on consent, opt-out of certain marketing communications, opt-out of sale or sharing of personal information, or opt-out of targeted advertising or certain profiling.

To submit a privacy request, contact privacy@richeymay.com or use any Privacy Rights Request form or Privacy Center mechanism we make available. We may request information necessary to verify your identity and process the request. Authorized agents may submit requests where permitted by law, subject to verification and proof of authorization.

We may deny or limit requests where permitted by law, including where we need to retain information for legal, regulatory, contractual, professional, security, fraud prevention, dispute resolution, or other permitted purposes. Where applicable, we will provide instructions for appealing a denied request.

YOUR GENERAL DATA PROTESTION REGULATION (GDPR) RIGHTS

This section applies to personal data of individuals in the European Economic Area, United Kingdom, or other jurisdictions with similar rights where we act as a data controller. Subject to applicable law and exceptions, you may have the following rights:

Access: the right to obtain access to your personal data.

Rectification: the right to ask for inaccurate or incomplete personal data to be corrected.

Erasure: the right to request that personal data be erased.

Restriction: the right to request restriction of processing in certain circumstances.

Objection: the right to object to certain processing, including processing for direct marketing.

Portability: the right to receive personal data in a portable format and transmit it to another controller where applicable.

Withdrawal of consent: the right to withdraw consent where processing is based on consent.

Complaint: the right to lodge a complaint with a supervisory authority where applicable.

You may exercise these rights by contacting the Data Protection Officer at privacy@richeymay.com.

PRIVACY POLICY FOR CALIFRONIA RESIDENTS

This section supplements the Privacy Policy and applies to California residents, where we are subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”). Terms used in this section have the meanings given under the CCPA.

California residents may have the right to know/access personal information, request deletion, request correction, request portability, opt out of sale or sharing of personal information, limit the use and disclosure of sensitive personal information where applicable, and not be discriminated against for exercising CCPA rights.

The categories of personal information we collect, disclose, use, or retain may vary depending on your interaction with us. During the preceding twelve (12) months, we may have collected the following categories:

Category	Examples	Purpose / Disclosure Context
Identifiers	Name, email, phone number, business address, online identifiers, IP address	Communications, services, marketing, events, security, administration, compliance.
Customer records information	Contact details, billing records, client relationship records	Service delivery, invoicing, account management, legal and professional obligations.
Commercial information	Services requested, event registrations, transaction history, preferences	Business development, service delivery, marketing, analytics.
Internet or network activity	Device, browser, log, cookie, analytics, and Site interaction data	Site operations, analytics, security, fraud prevention, marketing measurement.
Professional or employment-related information	Company, title, business role, professional contact details	Business communications, events, marketing, service delivery.
Geolocation data	Approximate location derived from IP address	Site analytics, security, localization, compliance.
Audio, electronic, or visual information	Voicemails, call recordings, meeting recordings, webinar participation where applicable	Communications, support, training, records, service delivery.
Sensitive personal information	Limited sensitive data only where voluntarily provided or necessary for services, compliance, security, or professional obligations	Used only for permitted purposes unless otherwise disclosed or required by law.

YOUR OPT-OUT CHOICES

If we use targeted advertising or sale/sharing Your Opt-Out Choices. If we sell or share personal information, including through certain analytics, advertising, or remarketing technologies, you may opt out by using the “Do Not Sell or Share My Personal Information” link in the Site footer or through our Privacy Preference Center. Where required by applicable law, we will also recognize the Global Privacy Control or another legally recognized universal opt-out mechanism.

To exercise California rights, contact privacy@richeymay.com or use any privacy request method we make available. We will verify and respond to requests as required by applicable law. You may designate an authorized agent to submit a request on your behalf, subject to verification and proof of authorization.

COLORADO PRIVACY ACT NOTICE

This section applies to Colorado residents where we are subject to the Colorado Privacy Act. Colorado residents may have the right to access personal data, correct inaccuracies, delete personal data, obtain a portable copy of personal data, and opt out of targeted advertising, sale of personal data, or certain profiling activities, subject to applicable exceptions.

To exercise Colorado privacy rights, contact privacy@richeymay.com or use any privacy request method we make available. We will authenticate requests as required by applicable law. If we deny a request, you may appeal the decision by following the appeal instructions included in our response.

Where required by applicable law, we will honor recognized universal opt-out mechanisms or other legally required preference signals for targeted advertising or sale of personal data.

OTHER STATE PRIVACY RIGHTS

Residents of other states may have similar privacy rights depending on applicable law and our role as controller, processor, business, service provider, contractor, or professional services provider. Where required, we will provide applicable rights, notices, request mechanisms, opt-out choices, appeals, and other disclosures consistent with applicable law.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. When we update the policy, we will revise the effective or updated date. For material changes, we will provide additional notice where required by law or where appropriate based on the nature of the change. We encourage individuals to review this Privacy Policy periodically to stay informed about how we help protect the personal information we collect.

YOUR CKNOWLEDGEMENT OF THIS PRIVACY POLICY

CONTACTING US

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at:

Richey May
Website: https://richeymay.com
Mail: 9780 S. Meridian Blvd Suite 500 Englewood, CO 80112
Phone: (303) 721-6131
Email: privacy@richeymay.com Attn: Richey May Data Protection Officer

MARKETING COMMUNICATIONS

You may request removal of your information from our marketing systems by contacting privacy@richeymay.com. If you request removal from marketing systems, we will take reasonable steps to remove you from marketing communications. Other information may be retained where necessary for business, legal, contractual, professional, security, compliance, or other permitted purposes.

This document was last updated on July 24, 2026.