Privacy Policy

1. Firm Identification

Wealth In Yourself LLC, doing business as Top Shelf Private Wealth ("TSPW," "the Firm," "we," "us," or "our"), is a Registered Investment Adviser with the State of Nevada. CRD #322123.

• Principal: Josh St. Laurent, MS, CFP®, CFT™, APFC®, ACC
• Principal Office: 195 Highway 50 STE 205, Zephyr Cove, NV 89448
• Contact (TSPW): josh@topshelfprivatewealth.com

2. Purpose and Scope

This Privacy Policy describes how we collect, use, disclose, and protect the nonpublic personal information ("NPI") and personal information ("PI") of our clients, prospective clients, and website visitors across both the Wealth In Yourself and Top Shelf Private Wealth brands. This policy is provided in accordance with Regulation S-P (17 CFR Part 248), the California Consumer Privacy Act ("CCPA"), and Nevada Revised Statutes Chapter 603A.

This policy applies to all information collected through our advisory services, our websites (wealthinyourself.com and topshelfprivatewealth.com), intake forms, communications, meeting recordings, technology systems used in the delivery of advisory services, and automated and artificial-intelligence-assisted systems used in our planning and operational workflows.

3. Categories of Information We Collect

3.1 Information You Provide Directly

• Full legal name, date of birth, Social Security number, and government-issued identification
• Contact information including mailing address, email address, and phone number
• Marital and family status, dependents, and beneficiary designations
• Employment, contract, and compensation details (including signing bonuses, deferred compensation, performance incentives, and trade-related compensation events)
• Assets, liabilities, net worth, and account information
• Investment objectives, risk tolerance, and time horizons
• Tax returns, estate planning documents, and insurance policies
• Business ownership details, entity structures, and operating agreements
• Real estate holdings and related financial data
• Banking and brokerage account numbers and statements
• For TSPW clients: jurisdiction-of-play history, agent contact and representation status, escrow contributions, contract structure, and family-of-origin and household-financial-support context relevant to financial life planning
• Values, life goals, and personal priorities shared during financial life planning sessions

3.2 Information We Collect Through Our Systems

• Meeting recordings and transcripts from video conference sessions
• Email communications and correspondence
• Intake form responses and questionnaire data
• Website browsing data, cookies, and analytics
• Scheduling and calendar information
• Signed agreements and contracts
• Billing and payment information
• Structured data fields and signal patterns extracted automatically from your communications and meeting transcripts — including action items, scheduling commitments, and financial figures referenced in conversation; life-event details and personal preferences mentioned during sessions; and financial life planning signals (for example, the specific language you use when discussing money, values-related statements, planning-relevant disclosures, and behavioral patterns that inform our advisory methodology). Where the precise language matters for planning purposes, verbatim quotes may be preserved alongside the structured signal. These signals are classified by type, stored in your client record, and subject to access controls limiting downstream use to advisory and relationship management functions.
• Operational context derived from interaction patterns (for example, frequency and timing of communications, response patterns, and engagement indicators that inform service delivery)

3.3 Information We Receive From Third Parties

• Account holdings, balances, and transaction data from custodians
• Credit and background information from reporting agencies (only with your consent)
• Account aggregation and transaction data from financial accounts you authorize through Plaid-enabled services such as Monarch Money
• Referral information from professionals in your service network (agents, CPAs, trainers, attorneys)

4. How We Use Your Information

• Providing personalized financial planning and investment advisory services
• Preparing financial plans, projections, and recommendations
• Executing investment transactions through our custodian
• Managing your client dashboard with meeting notes, action items, and deliverables
• Processing and summarizing meeting recordings and transcripts
• Drafting and sending communications related to your advisory engagement
• Generating and managing billing and invoicing
• Complying with regulatory requirements, including recordkeeping obligations
• Aggregating context across our systems before client meetings to support thorough preparation
• Extracting structured information from communications and meetings to populate client records and reduce manual entry
• Surfacing relationship-care moments based on patterns and personal details we observe in your communications and meetings — including life milestones, personal preferences, and relationship details you share — to support thoughtful, personalized advisory service. An automated process queues candidate relationship-care moments for advisor review before any action is taken; no gesture is sent without Josh's direct authorization.
• Improving our advisory processes and client experience
• Marketing our services (only with aggregated, de-identified data; never your personal details)

5. Artificial Intelligence and Technology Disclosure

5.1 Categories of AI Usage

We use artificial intelligence systems, primarily Anthropic's Claude, to support the following advisory and operational functions:

• Meeting transcript summarization — generating summaries of recorded meetings for advisor review and client deliverables
• Action item and structured data extraction — identifying commitments, dates, decisions, and other structured information from meeting transcripts and communications
• Email triage and drafting — categorizing inbound communications and drafting response options for advisor review
• Content creation and review support — drafting marketing communications, blog posts, and educational content for advisor review prior to publication
• Dashboard and workflow management — automating routine record-keeping operations
• Scheduling and calendar automation — facilitating meeting coordination
• Financial plan preparation support — drafting components of financial plans and analyses for advisor review and refinement
• Pre-meeting context aggregation — assembling relevant prior context from across firm systems to support advisor preparation
• Real-time in-meeting advisory query— during live client meetings, Josh may query an AI system with short, advisor-facing questions to surface relevant prior signals and methodology prompts from your client record. This surface is operator-facing only (displayed on Josh's secondary device, not visible to you); you do not interact with the AI system directly. Queries are limited per meeting and audit-logged. This surface is subject to your AI processing consent under Section 14.
• Hospitality moment surfacing — identifying opportunities for relationship-care gestures based on patterns observed in our interactions

5.2 Human Oversight Commitment

All AI-generated outputs that are client-facing or that inform advisory recommendations are reviewed by Josh St. Laurent before delivery to you. AI systems do not autonomously send communications, execute transactions, or render advice without advisor review.

5.3 AI Data Handling

Client data processed by AI systems is subject to the same confidentiality protections that apply to all client data under this policy. Our AI processing relationship with Anthropic operates under contractual terms that prohibit use of customer inputs and outputs for AI model training. We do not use client data to train AI models. We do not sell, share, or otherwise disclose client data to third parties for AI training or development purposes.

6. Third-Party Service Providers

We engage third-party service providers in the delivery of our advisory services, including custodians (Altruist), CRM (GoHighLevel), internal workspace (Notion), cloud workspace (Google Workspace), database and authentication platform (Supabase), financial planning software (RightCapital), cash flow management (Monarch Money, Sequence), AI processing (Anthropic), video conferencing and transcription (Zoom), digital signatures (Adobe Sign, transitioning to GoHighLevel Documents), accounting (QuickBooks Online), intake forms (Involve.me), newsletter distribution (Substack), web hosting and operational portal infrastructure (Vercel), authentication session storage (Upstash Redis), transactional email (Resend), content delivery and DNS (Cloudflare), workflow automation (Zapier), and website analytics (Google Analytics GA4). Each provider receives only the minimum information necessary to perform its function. We maintain written agreements with service providers who handle nonpublic personal information that include contractual data protection requirements consistent with applicable regulations, including amended Regulation S-P.

A current, detailed provider table is available on request and is mirrored on wealthinyourself.com/privacy-policy.

7. Disclosure of Your Information

7.1 We Do Not Sell Your Personal Information

We do not sell, rent, or trade your nonpublic personal information or personal information to any third party for any purpose.

7.2 Permitted Disclosures

• To our custodian and service providers as necessary to deliver advisory services
• To comply with applicable laws, regulations, or legal proceedings
• To respond to regulatory examinations or investigations
• To protect our rights, privacy, safety, or property
• With your express written consent

7.3 Opt-Out Rights

You have the right to opt out of certain information sharing. To exercise this right, contact us at josh@topshelfprivatewealth.com. We will process your request within 30 days.

8. California Consumer Privacy Act (CCPA) Disclosures

If you are a California resident, you have the right to know what personal information we collect, the right to request deletion, the right to non-discrimination, and the right to opt out of AI processing (Section 14). We have not sold personal information in the preceding 12 months and do not sell personal information. To exercise CCPA rights, contact josh@topshelfprivatewealth.com; we will verify your identity before processing and respond within 45 days.

9. Data Retention

We retain client advisory records for a minimum of 5 years from last activity; financial plans for 6 years; meeting recordings and transcripts for the duration of the engagement plus 5 years; marketing records for 5 years from last use; billing records for 7 years; communications and audit logs for 5 years from creation (with the first 2 years easily accessible per Books and Records Rule 204-2). AI processing inputs and outputs are subject to a brief retention period under Anthropic's commercial terms (typically 30 days for safety review) before deletion from Anthropic's systems.

10. Data Security

We protect your information with encryption in transit (TLS/SSL) and at rest, multi-factor authentication on all systems containing client data, role-based access controls, database-level row-level security, application-level audit logging, regular review of third-party security practices, designed US data residency, secure disposal of records, encrypted devices, ongoing monitoring for unauthorized access, and a written incident response plan covering detection, containment, notification, and remediation.

11. Breach Notification

In the event of a data breach affecting your personal information, we will notify you as promptly as practicable and in no case later than 30 days after we determine a breach has occurred that requires notification, in accordance with the SEC's amended Regulation S-P (effective June 3, 2026) and Nevada Revised Statutes Chapter 603A. This obligation extends to prospective clients whose nonpublic personal information may have been affected. We will also notify the Nevada Attorney General and any other regulators with notification rights.

12. Annual Notice

We will provide you with a copy of this privacy policy annually, as required by Regulation S-P. The most current version is always available at topshelfprivatewealth.com/privacy and wealthinyourself.com/privacy-policy.

13. Website Cookies and Tracking

Our website may use cookies and similar tracking technologies. We use Google Analytics (GA4) and similar tools to understand visitor interactions. This data is collected in aggregate and does not identify individual visitors. When you submit your email address to receive a resource or subscribe to our newsletter, your email is used solely for that purpose; you may unsubscribe at any time. You may disable cookies in your browser settings.

14. Your Consent to AI Processing

By engaging our advisory services, you consent to the use of artificial intelligence tools as described in Section 5. You may request that we suspend AI-assisted processing of your data at any time by contacting josh@topshelfprivatewealth.com. Upon receipt of an opt-out request, your client record will be flagged to exclude AI processing across our systems; manual handling will replace automated processing for your account; continuation of advisory services will not be affected. We will confirm receipt within five business days and confirm operational implementation within thirty days. You may revoke an opt-out at any time.

15. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website and, for current clients, by providing notice through our regular communication channels.

16. Contact Us

Wealth In Yourself LLC
(DBA Top Shelf Private Wealth)
Josh St. Laurent, MS, CFP®, CFT™, APFC®, ACC
195 Highway 50 STE 205
Zephyr Cove, NV 89448
Email: josh@topshelfprivatewealth.com

17. Automated Decisioning and Data Subject Rights

Our advisory services are delivered by Josh St. Laurent personally. While AI systems support our operations, no decision affecting your account, your investments, your fees, or your advisory relationship is rendered by an AI system without human review and approval. You have the right to know how AI is used, the right to opt out, the right to human review of any AI-generated output about your account, and the right to challenge AI outputs you believe inaccurately reflect your situation.

This HTML version is authoritative for the Wealth In Yourself / Top Shelf Private Wealth combined practice.