Legal — Annual Notice

GLBA Privacy Notice

Last updated: June 2026 • Issued annually as required by Regulation P

What does Fidelis Solutions Group, LLC do with your personal financial information? Federal law gives consumers the right to limit some but not all sharing of their nonpublic personal information (NPI). Federal law also requires us to tell you how we collect, share, and protect your NPI. Please read this notice carefully to understand what we do.

What Information We Collect

We collect NPI about you from the following sources:

Information you provide on applications or other forms (e.g., name, address, SSN, income, assets).
Information about your transactions with us or our affiliates (e.g., account balances, payment history, investment activity).
Information we receive from consumer reporting agencies or credit bureaus (for lending inquiries).
Information obtained from third-party financial data aggregators (Plaid, MX) when you authorize account linking.
Tax return information and IRS records obtained with your written authorization (Form 8821 / 2848).

How We Share Your Information

All financial companies need to share clients' personal financial information to run their everyday business. The table below lists the reasons we can share your NPI, whether we share it, and whether you can limit this sharing.

Reasons we can share your NPI	Do we share?	Can you limit this sharing?
For our everyday business purposes — to process your transactions, maintain your accounts, respond to court orders and legal investigations, or report to credit bureaus.	Yes	No
For our marketing purposes — to offer our products and services to you.	Yes	No
For joint marketing with other financial companies	No	We don't share
For our affiliates' everyday business purposes — information about your transactions and experiences.	Yes	No
For our affiliates' everyday business purposes — information about your creditworthiness.	No	We don't share
For our affiliates to market to you	No	We don't share
For non-affiliates to market to you	No	We don't share

How to Limit Our Sharing

If you are a new client, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our client, we continue to share your information as described in this notice.

However, you can contact us at any time to limit our sharing:

Email: legal@fidelis.tax

Please note that federal law gives you the right to limit only sharing for affiliates' everyday business purposes based on creditworthiness, affiliates' use of your information to market to you, and sharing with non-affiliates for their marketing purposes. We do not engage in those types of sharing.

How We Protect Your Information

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include:

Encryption of sensitive data (including SSNs and financial account data) at rest and in transit.
Role-based access controls limiting access to NPI to personnel who need it to perform their duties.
Physical, administrative, and technical safeguards as required by the GLBA Safeguards Rule (16 C.F.R. Part 314).
Regular risk assessments and security monitoring.
Contractual obligations requiring service providers to maintain equivalent safeguards.

Who We Are

This notice is provided by Fidelis Solutions Group, LLC on behalf of the Fidelis family of companies, including Fidelis Advisory Services, LLC (loan brokerage), Fidelis Tax and Accounting, Fidelis Capital Services, Fidelis Wealth AI, LLC and Fidelis Wealth Group, LLC, and The Phoenix Program. These entities share common ownership and operate as affiliates under a coordinated privacy program.