Updated: October 9, 2026
Welcome to Warmer and FinanceHQ!
Relationships are everything, and your trust is important to us. This Privacy Policy explains, in plain language, what information we collect, how we use it, when we share it, and the choices available to you.
Warmer Holdings Inc. (“Warmer”) operates the Warmer websites, advisor directory, technology platform, and related services. FinanceHQ LLC (“FinanceHQ” or “FHQ”) is Warmer’s wholly owned subsidiary and an SEC-registered investment adviser. This Policy applies to both companies and to their websites, applications, directory, matching and referral tools, accounts, communications, and related services (together, “us” and our “Services”). We may provide this policy through our websites, email, or another legally permitted method.
We serve three groups of customers:
Advisors operate as separate businesses. They have their own legal obligations and privacy practices.
Our Services are intended for adults in the United States.
The information you share. We collect information you provide when you use our Services, complete a form or questionnaire, request an Advisor match, create an account, communicate with us, or otherwise interact with us. This may include your name, email address, telephone number, location, household information, goals, preferences, and communications.
Financial and advisory information. For FinanceHQ advisory clients, we may collect information such as income, net worth, investable assets, assets under management, account values, financial goals, risk preferences, requested services, recommendations, agreements, advisory notes, and related communications. This information may be “nonpublic personal information” under Regulation S-P.
Public Advisor information. We collect professional information from regulatory filings, firm websites, public records, professional directories, licensed databases, third-party sources, and Advisors. This may include names, firms, business contact information, registrations, licenses, employment and education, services, fees, minimums, credentials, and disciplinary or regulatory history.
Account and business information. For Clients and Advisors with accounts, we collect login and verification records, profile submissions and corrections, contracts, billing details, payment information, and support communications.
Referral and relationship information. We collect information about Advisors shown, saved, selected, or contacted; introductions and referrals; meeting and follow-up activity; whether a relationship was established; referral attribution; and assets, advisory fees, revenue, billing, or compensation information needed to administer and verify our arrangements.
Website and device information. We collect pageviews and limited events, online or device identifiers, cookies and similar technologies, browser and device information, Internet Protocol address, approximate location, marketing source and campaign information, email and application activity, and product feedback.
Connected information. If a Client enables an integration, we may process information made available through it. Depending on the Client’s settings, this can include CRM profiles, tasks, notes, email or calendar information, specified documents, transcripts, and other information associated with the Client’s business or advisory relationships.
Communications and payments. We collect sales, service, support, and compliance communications, along with the billing and transaction information needed to process payments and administer our relationships.
We collect information directly from you; from Warmer, FinanceHQ, participating Advisors, advisory firms, and authorized integrations; automatically through our Services; and from lawful public, regulatory, licensed, or third-party sources.
We use the information we collect to:
No. We do not disclose Clients’ nonpublic personal information to nonaffiliated third parties for their own independent marketing except as described in this Policy, our Terms of Service and Advisory Agreement, with the Client’s direction or consent, or as otherwise permitted by law. These practices also apply to Visitors and former Clients.
We apply safeguards consistent with Regulation S-P and our internal information-security standards to protect Client and Advisor information.
We collect nonpublic personal information in connection with requested or provided financial services and advice. We use this information to evaluate and establish advisory relationships, provide advice and related services, maintain records, satisfy fiduciary and regulatory obligations, and protect our business and clients.
When a Visitor chooses to be matched, contacted, or considered for services, we first establish a Client relationship, and the Client acknowledges our Terms of Service and FHQ Advisory Agreement. We may then share with Advisors the information needed to evaluate or complete the requested introduction to selected or matched Advisors.
Requesting a referral is optional, and you choose whether to proceed. If you do, the information shared may include contact details, financial profile information, goals, preferences, questionnaire responses, and related communications. By submitting the request, you direct us to make the disclosures reasonably necessary to provide the match, introduction, or requested service. We cannot complete a requested introduction if the needed information is withheld.
We may receive compensation for leads, introductions, assets, or revenue resulting from relationships. This creates a financial incentive to make referrals, including to Advisors that pay us or from whom we expect to receive more compensation. You are not required to contact or hire any Advisor we identify.
Referral sharing is separate from our marketing activities. We do not sell referral information to data brokers or advertising partners. We disclose it only to contracted Advisors to evaluate and complete a match or introduction you requested. Participating Advisors may use the information to follow up on that request and are subject to applicable contracts, professional standards, and privacy obligations. If an advisory relationship is established, the Advisor is responsible for applicable fiduciary duties. Any compensation is for the referral, introduction, or resulting relationship—not permission to use the information for unrelated marketing.
We may create and maintain Advisor profiles using regulatory filings, firm websites, professional directories, public databases, licensed sources, and other lawful public information. An Advisor does not need to create an account, claim a profile, or enter into a commercial relationship with us for a profile to appear.
An Advisor who claims or creates an account may edit or supplement designated profile fields and may ask us to correct objectively inaccurate information. We may verify a requested change against public or authoritative sources.
We distinguish between public information and nonpublic information supplied through an Advisor account. We may retain, organize, and display accurate public-source and platform-generated information even if an Advisor has not claimed the profile or later closes an account.
We do not publish nonpublic account information unless it is identified as a public profile field, is otherwise lawfully public, or the Advisor asks us to publish it.
Claiming a profile does not give an Advisor editorial control over our directory, public-source information, platform-generated information, or the way our Services are organized and presented. Closing an account does not automatically remove an Advisor’s public profile.
An Advisor may unclaim a profile or otherwise end participation in Advisor services. Unclaiming ends the Advisor’s control of the claimed profile and may remove its claimed or verified status. It does not automatically disable the Advisor’s login, end any separate Client relationship, or require us to remove accurate information obtained from public or authoritative sources.
Upon request, we may remove private or Advisor-submitted profile information that is no longer needed, subject to applicable legal, regulatory, security, dispute-resolution, and recordkeeping requirements. Advisors may continue to request correction of objectively inaccurate profile information.
Our Terms of Service and Advisory Agreement provide additional information about Advisor-submitted content, profile management, corrections, and use of our Services.
We use contracted service providers for hosting, storage, data processing, integrations, communications, support, security, billing, analytics, and AI-assisted features. We keep Client information within our approved systems and contracted service-provider environment. Our SOC 2 control framework covers how we select, authorize, monitor, and use those providers and how information moves between approved systems.
Technology service providers that handle sensitive information are required to maintain current SOC 2 Type II reports or comparable independent assurance. We review relevant reports and controls as part of our vendor oversight.
We use advertising and analytics partners, including social-media advertising platforms, for measurement, audience matching, and advertising. Privacy Settings identifies our current advertising partners and provides available controls.
For Visitors, these partners may receive online identifiers, cookies or similar identifiers, pageview or limited event information, and related device, browser, network, or Internet Protocol address information. We do not send a Visitor’s financial profile, advisory questionnaire responses, or other financial-advisory nonpublic personal information for pageview tracking or audience matching.
For Clients, advertising partners may also receive limited contact identifiers, such as name, email address, telephone number, or home country, together with limited conversion or account-event information. We do not send financial account values, financial profiles, advisory objectives, recommendations, advisory notes, or similar financial-advisory information for advertising or audience matching.
We do not sell personal information to advertising partners or data brokers. Advertising partners may process the limited information described above to provide measurement, matching, audience, and advertising services. Visitors and Clients may turn pageview tracking and audience matching off or back on through Privacy Settings.
We may also disclose information when reasonably necessary or legally required to regulators, law enforcement, courts, auditors, insurers, attorneys, accountants, consultants, and other professional advisers. Information may be transferred as part of a financing, merger, acquisition, reorganization, sale of assets, bankruptcy, or similar transaction, subject to applicable law and appropriate protections.
Pageview tracking and audience matching. Visitors and Clients may turn pageview tracking and audience matching off or back on.
Marketing emails, calls, and texts. Anyone receiving marketing emails, calls, and texts may unsubscribe or, where available, subscribe again. We may still send service, transactional, compliance, security, and legal communications.
These settings may be enabled by default where permitted by law. Where prior consent is required, we will ask before enabling the applicable technology.
Visitors can manage their choices through Privacy Settings. We associate those choices with a session, online identifier, and, when available, a Visitor identifier. A choice stored only in a browser or session may not follow someone to a different device or browser until we can reliably connect the records.
When a Visitor becomes a Client, we carry identifiable preferences into the Client’s account instead of resetting them. Clients can then manage their preferences through account management.
We keep your current preference settings and the date each setting was last changed. We may also retain limited records needed to honor your choices, prevent accidental re-enrollment, and comply with legal obligations.
Applicable law may provide additional rights concerning access, correction, deletion, portability, or certain uses or disclosures of personal information. We will honor those rights when they apply to us, subject to identity verification, legal exceptions, and required retention.
Privacy Settings are available here.
Yes. Clients may end Client Services through account management or by contacting us.
Ending Client Services terminates the Client’s advisory agreement with us in accordance with that agreement. It also stops new Advisor matches, non-required Client communications, marketing, and advertising-related matching associated with the Client profile. Where reasonably possible, we will withdraw pending Advisor introductions and stop further follow-up concerning them.
A former Client may continue to sign in to manage privacy preferences, use any publicly accessible prospect or separate Advisor features, and to re-enable Client services. A former Client who wishes to use Client services again must complete our then-current enrollment process, receive the applicable disclosures, and enter into a new advisory agreement.
Ending Client services with us does not terminate a Client’s separate agreement or relationship with an independent Advisor. The Client must contact that Advisor directly to end any such relationship. Information provided to an Advisor before the Client relationship ended cannot always be retrieved or recalled.
Ending Client services does not immediately delete all information. We may retain Client records, agreements, consents, disclosures, communications, billing and compensation information, advice and recommendations, and other information required or reasonably necessary for legal, regulatory, tax, audit, security, fraud-prevention, dispute-resolution, enforcement, and recordkeeping purposes.
Clients may separately contact us to request deletion of eligible information or exercise any privacy rights that apply to them. We may continue to send communications necessary to administer retained records, protect account security, comply with law, or provide required disclosures.
Because an Advisor may also be a Client, ending Client services does not by itself unclaim the Advisor’s profile or end the Advisor’s participation in Advisor services. Advisors may separately unclaim their profiles or end Advisor participation as described in our Terms.
No. We do not use Visitor, Client, or Advisor information to train generalized artificial-intelligence or machine-learning models. This includes information provided directly to us and information received through authorized integrations.
We may use enterprise or API-based AI providers to process information and provide or improve our Services. We configure or contract for those services so that information submitted by us is not used to train the provider’s generalized models.
We use administrative, technical, and physical safeguards designed to protect information. These include encryption in transit and at rest, access controls, role-based provisioning and deprovisioning, multi-factor authentication where available, monitoring, incident-response procedures, provider assessment, and contractual or technical protections.
Production systems and Client information are limited to authorized personnel and providers with a legitimate operational, security, service, or compliance need. Data and personnel are primarily based in the United States. Integrations may use protected access tokens or similar credentials; we do not store passwords used to access third-party systems.
We retain information for as long as reasonably necessary to provide our Services, administer accounts and referrals, maintain accurate public and regulatory records, calculate and verify compensation, satisfy legal and regulatory obligations, resolve disputes, protect security, and enforce agreements. Retention may continue after an account, advisory relationship, or commercial relationship ends.
When information is no longer needed, we delete or de-identify it in accordance with our data-management practices. No security measure can guarantee absolute security, so please notify us promptly if you believe your information or account has been compromised.
Your privacy settings cover pageview tracking, audience matching, and marketing communications.
If you become a Client, your identifiable settings carry into your account.
Advisor profiles may exist without an account, and accurate public information may remain after an account is closed.
We may provide matched advisors with your contact information, profile information, and responses so they can understand your financial goals and follow up with you.
We do not send financial profiles, advisory objectives, recommendations, or advisory notes to advertising partners for advertising or audience matching.
We do not use Visitor, Client, or Advisor information to train generalized AI models.
Clients may close an account and ask us to delete eligible information, but we retain records required for legal, regulatory, security, and compliance purposes.
We may update this Policy as our Services, practices, or legal obligations change. We will post the current version and update the date above. If a change is material, we will provide additional notice or obtain consent when required by law.
Relationships are everything, and your trust is important to us. If you have any questions or privacy requests, please contact us at [email protected] or [email protected].
Warmer Holdings Inc. and FinanceHQ LLC
1460 Broadway
New York, NY 10036