Privacy Policy

Who We Are

Mastermind Virtual Family Office LLC (“Mastermind VFO,” “MMVFO,” “we,” “our,” “us”) provides family office and concierge services. We are not a certified public accounting firm, registered investment adviser, or licensed insurance agency. Instead, we may introduce you to or coordinate with affiliated companies or trusted third parties (collectively, “Affiliates”) that provide CPA, investment advisory, insurance, or related services.

This Privacy Policy explains how we collect, use, share, and protect your information in compliance with U.S. federal and state privacy requirements and financial industry standards.

Information We Collect

We collect information directly from you, from your communications with us, and from website interactions. Categories include:

• Identifiers: name, address, email, phone number, date of birth
• Financial data: income, assets, liabilities, net worth, investment goals, tax jurisdiction, account details
• Insurance data: application forms, claims history, policy needs
• Professional information: employment, business interests, and affiliations
• Communications data: SMS/text, emails, phone call logs, and form submissions
• Technical information: IP address, browser/device data, usage patterns, cookies
• Sensitive personal information (SPI): government IDs (SSN, driver’s license), account numbers, health-related data for insurance (only when provided)

How We Use Your Information

We use your information for legitimate business purposes, including:

• Responding to inquiries and requests
• Evaluating eligibility for services offered by our Affiliates
• Facilitating introductions and sharing information with Affiliates
• Conducting due diligence for compliance, anti-money laundering (AML), and know-your-customer (KYC) requirements
• Providing family office coordination services
• Communicating about services and events (with appropriate consent)
• Meeting legal and regulatory obligations
• Protecting against fraud and security threats

We do not use or disclose your information for unrelated purposes without notice and, where required, consent.

Sharing Your Information

We may disclose your personal information as follows:

• Affiliates: CPAs, investment advisers, insurance agencies, or other licensed professionals, for the purpose of providing requested services
• Service providers: IT, hosting, CRM, analytics, compliance, and administrative vendors under strict confidentiality
• Regulators and legal authorities: where required by law, regulation, subpoena, or court order
• Professional advisors: auditors, attorneys, or consultants

We do not sell or rent your personal information to third parties.

SMS Consent: SMS consent is not shared with third parties or affiliates.

Marketing & Communications

• Email: We comply with CAN-SPAM. Marketing emails include our mailing address and a functional unsubscribe link. Transactional/service emails may continue where legally permitted.
• SMS/Text: If you opt in, message frequency may vary. Msg & data rates may apply. Reply STOP to cancel, HELP for help. SMS consent is not required to purchase services. SMS consent is not shared with third parties or affiliates.
• Phone/Voicemail: Calls may be recorded for compliance and quality assurance.

Data Security

We maintain a written Information Security Program with administrative, technical, and physical safeguards designed to:

• Encrypt data at rest and in transit
• Restrict access to authorized personnel only
• Conduct periodic risk assessments, audits, and penetration testing
• Maintain backup, disaster recovery, and incident response protocols
• Comply with FTC Safeguards, SEC/FINRA Reg S-P and Reg S-ID, IRS Publication 4557, and NAIC cybersecurity standards where applicable

Data Retention

We retain information only as long as necessary to:

• Fulfill the purposes described in this policy
• Comply with regulatory recordkeeping requirements (e.g., SEC/FINRA, IRS, NAIC)
• Resolve disputes and enforce agreements

Typical retention: 5–7 years, unless a longer period is legally required.

Legal Basis for Processing

We process personal data on the following grounds:

• Consent: When you voluntarily provide information or opt into communications
• Contractual necessity: To facilitate services requested through our Affiliates
• Legal obligation: Compliance with financial, tax, and insurance regulations
• Legitimate interests: Operating, securing, and improving our business

State Privacy Rights

Residents of states with privacy laws (CA, CO, CT, VA, TX, FL, and others) may have rights, including:

• Access/Know what data we hold
• Correction of inaccuracies
• Deletion of personal information (with exceptions)
• Portability (receive a copy in a usable format)
• Opt-out of targeted advertising or sale/sharing of personal data (we do not sell/share for these purposes)
• Limit use of sensitive personal information (we do not use SPI for advertising)

Requests can be submitted via email at privacy@mmvfo.com. We honor Global Privacy Control (GPC) signals where applicable.

Cookies & Online Tracking

We use cookies and analytics tools to improve our site. You may manage cookies via your browser or our cookie banner. We do not use cookies to sell/share data for cross-context advertising.

Children’s Privacy

Our services are intended for adults. We do not knowingly collect information from individuals under 13.

Your Choices

• Email: Use unsubscribe links or contact us
• SMS: Reply STOP to cancel
• Data requests: Email privacy@mmvfo.com or use our web form
• Authorized agents: You may use an agent to submit requests, subject to verification

We will not discriminate against you for exercising your rights.

Contact Us

Changes to This Policy

We may update this policy periodically. Updates will be posted at mmvfo.com/privacy-policy with a revised “Effective Date.”

Placement & Accessibility

• A link to this Privacy Policy appears in the footer of every page on mmvfo.com.
• A link is placed next to consent language on all forms that collect personal information, especially where SMS consent is requested.
• Accessible to all users, including those with disabilities, per ADA/WCAG standards.