Privacy policy.
How Holden Family Office collects, uses and protects your personal information.
Holden Family Office LLC is a registered investment adviser. Protecting the confidentiality and security of what you entrust to us is fundamental to how we work. This notice explains what personal information we collect, why we collect it, how we use and share it, and the choices you have.
It applies to prospective clients, clients and former clients, and to anyone who visits holdenfamilyoffices.com.
Information we collect
Information you give us
When you contact us through this website, we collect your name, email address, telephone number, how you heard about us, the nature of your inquiry, an indication of your portfolio size, and whatever you choose to write in your message.
If you become a client, we collect what is necessary to open and service your accounts — typically your address, date of birth, Social Security or taxpayer identification number, occupation and employment status, financial goals, assets, income, liabilities, tax situation, and information about your family and intended beneficiaries.
Information about your transactions
Account balances and holdings, transaction and trading history, wire transfer and disbursement instructions, and your history of dealings with us and with others.
Information from third parties
Custodians, broker-dealers and other financial institutions that hold your assets; consumer reporting agencies; and the professionals who work alongside us at your direction, such as your attorney, accountant or trustee.
Information collected automatically
Our web server keeps standard technical records when you visit — IP address, browser type, the pages requested, and the date and time. When you submit the contact form we also record the IP address it came from, which is how we identify automated abuse.
Cookies and tracking
This website sets no cookies. It uses no advertising pixels and no third-party analytics. We do not track you across other websites and we do not build advertising profiles. Because nothing here tracks you in the first place, a “Do Not Track” browser signal does not change what happens when you visit.
Typefaces are delivered by Google Fonts, which receives your IP address in order to serve them. The site also links out to LinkedIn, FINRA BrokerCheck and our client reporting portals. Those organizations have their own privacy practices, which this notice does not cover.
How we use your information
- To respond to your inquiry and determine whether we are a good fit for one another
- To provide advice, manage your accounts and execute transactions
- To open and maintain accounts with custodians and other unaffiliated third parties on your behalf
- To produce the reports, statements and communications you receive from us
- To verify your identity and protect your accounts against fraud, unauthorized access and identity theft
- To meet our obligations under federal, state and self-regulatory requirements, including recordkeeping, anti-money-laundering and tax reporting
- To keep you informed about services that may be of interest to you
We do not sell your personal information. We do not sell or rent client lists, and we do not give your name to telemarketers.
How we share your information
We do not disclose non-public personal information about our clients or former clients to anyone, except in the following circumstances:
- To entities that perform services for us or function on our behalf — including custodians, clearing broker-dealers, portfolio accounting and performance reporting platforms, investment companies, insurance companies and technology providers
- To consumer reporting agencies
- To your attorney, trustee, accountant or anyone else who represents you in a fiduciary capacity, at your direction
- To our own attorneys, accountants, consultants and auditors
- To government agencies, regulators and self-regulatory organizations in response to subpoenas, examinations or other legal process, or to comply with regulatory inquiries
- To anyone else, with your consent or at your direction
Where we engage a service provider, we require it to protect your information and to use it only for the purposes we specify.
Affiliate marketing
Under Regulation S-AM, a registered investment adviser may not use eligibility information received from an affiliate to make a marketing solicitation unless that use has been clearly disclosed, you have been given a reasonable opportunity to opt out, and you have not opted out. Holden Family Office does not receive eligibility information from affiliates for marketing purposes.
How we protect your information
We maintain physical, electronic and procedural safeguards designed to protect your information against unauthorized access and misuse. These include secured files and offices, access controls on our systems, and restricting access to those who need it in order to serve you. We review these safeguards as our business and the technology we rely on change.
If a security incident affects your personal information, we will investigate it and notify you and the appropriate authorities as required by applicable law.
No method of transmitting information over the internet is completely secure. Please do not send your Social Security number, account numbers or other sensitive details by ordinary email or through the contact form on this site. If you need to send us something sensitive, call us and we will arrange a secure method.
How long we keep your information
We keep your information for as long as you are a client, and afterwards for as long as we need it to meet our legal, regulatory and recordkeeping obligations — including the books and records requirements that apply to us as a registered investment adviser — and to resolve disputes or enforce our agreements.
Former and inactive clients
If you close your accounts or become an inactive client, this notice continues to apply to the information we hold about you.
Your choices
- Marketing. You can ask us to stop sending you marketing communications at any time, and every email we send includes a way to unsubscribe.
- Accuracy. If anything we hold about you is wrong or out of date, tell us and we will correct it.
- Access. You can ask us what personal information we hold about you.
State privacy rights
Most of the information we collect in the course of advising you is governed by the Gramm-Leach-Bliley Act and Regulation S-P, and is therefore exempt from a number of state consumer privacy laws, including the California Consumer Privacy Act.
Where a state law does apply — for example to information collected through this website that falls outside those rules — residents of California and of other states with comprehensive privacy laws may have the right to know what we collect, to request deletion or correction, and to opt out of the sale or sharing of personal information. We do not sell personal information and we do not share it for cross-context behavioral advertising. To make a request, contact us using the details below. We will not treat you differently for exercising these rights.
Children’s privacy
This website is not directed to children, and we do not knowingly collect personal information from anyone under 18.
Complaints
If you have a concern about how we have handled your information, please raise it with Sean Meunier at Holden Family Office LLC, by email at info@holdenfamilyoffices.com or by telephone on (413) 427-0331. We take complaints seriously and will respond promptly.
Changes to this notice
If we make a substantive change to how we use or share confidential information, we will update this page and revise the date below. Where the change is material, we will notify clients directly, as required by Regulation S-P.
Contact us
Questions about this notice may be directed to Holden Family Office at info@holdenfamilyoffices.com or (413) 427-0331.
Last updated: September 2026