Privacy Policy
ABG, LLC ("ABG" or the "Firm") understands that our clients' privacy is important and we are committed to maintaining their confidentiality. The following disclosure explains our policy regarding non-public information and the process we have in place to protect our clients' privacy and the confidential information we receive from our clients.
We collect non-public information about clients and counterparties from various sources ("Personal Data"), which include the following:
- Information we receive on applications and other forms (such as name, address, e-mail address, telephone number, Social Security Number, assets and income);
- Information about our clients' financial transactions with us or others; and
- Information that we received from non-affiliated third parties (such as credit rating agencies) or other entities who may service our clients' accounts from time to time.
We may use our clients' information in order to operate our business in a prudent manner in accordance with industry standards and applicable law, which may include servicing and maintaining accounts and transactions, offering a broad range of services and products, verifying income and assets, responding to inquiries and requests, preventing fraud, monitoring and archiving communications and verifying our clients' identity in accordance with the USA PATRIOT Act and the Know Your Customer requirements in our other regulated jurisdictions.
We do not disclose any non-public information to any non-affiliated third parties other than as permitted by law. We may disclose or share non-public information about our clients to our affiliates or third parties involved in servicing our clients' accounts. We do not otherwise provide information about our clients to outside firms, organizations or individuals except to our attorneys, accountants and auditors and as permitted by law. We will, however, release information about our client if directed to do so by such client or if compelled or required to do so by law or self-regulatory organization ("SRO") regulations.
We restrict access to our clients' information to those employees who need to know such information to provide products or services to our clients. We maintain physical, electronic and procedural safeguards to guard and protect all clients' information from unauthorized access, accidental or intentional manipulation, loss and destruction. Employees who violate these policies are subject to disciplinary action, including termination. Our clients' information is secure and is not shared with a third party unless such third party is involved in servicing our clients' relationship with ABG or as required, in limited situations, by law or SRO regulations.
CHOICES AND ACCESS
If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt-out by contacting your client relationship manager, primary point of contact or email: accounts@abgadvisory.com. Please note we will still send you important administrative and service or transaction-related messages, which you cannot opt out of.
How individuals can access, change or suppress their Personal Data: If you would like to request a review, correct, update, suppress, restrict or delete Personal Data that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact accounts@abgadvisory.com. We will respond to your request consistent with applicable law. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for recordkeeping and regulatory purposes.
RETENTION PERIOD: We will retain Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with our client and service their account(s); (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of applicable statutes of limitations, or regulatory investigations.
Summary & Disclosure of Business Continuity Plan
ABG has prepared, and has always maintained a current Business Continuity Plan ("BCP") in compliance with Financial Industry Regulatory Authority ("FINRA") Rule 4370. This document outlines our plans to continue our business and meet our existing obligations to our clients in the event of a significant business disruption ("SBD"). Our BCP is summarized below:
ABG's policy is to respond to a SBD by safeguarding our employees' lives and our property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of our books and records and allowing our clients to transact business. We will make every reasonable effort to meet our obligations to our clients at all times. We have in place a BCP that outlines essential parts of our business and discusses in detail:
(1) Data back-up and recovery (hard copy and electronic);
(2) All mission critical systems;
(3) Financial and operational assessments;
(4) Alternate communications between our clients and us;
(5) Alternate communications between our employees and us;
(6) Alternate physical location of our employees;
(7) Critical business constituents, banks, and counter-party impact;
(8) Regulatory reporting;
(9) Communications with regulators; and
(10) How ABG shall assure our clients' prompt access to their funds and securities (if applicable) in the event that we determine that we are unable to continue our business.
During the time that ABG may not be in operation, we shall provide alternative contact information to our clients via our website at www.abgadvisory.com for any required activity.
Customer Identification Program
To help the U.S. government fight the funding of terrorism and money laundering activities, Federal law requires all U.S. financial institutions, such as ABG, to obtain, verify and record information that identifies each individual or institution that establishes a customer relationship with such financial institutions.
If a client enters into a customer relationship with ABG, we will request certain financial and legal information about such client, including such client's legal name, tax identification number and address, and the identity of any individuals with any authority or control over such client. We also verify such information to the extent required as follows:
- Taking steps to check the information provided – to verify that the clients are who they say they are.
- Consult applicable governmental agency lists of known or suspected criminals, terrorists and terrorist organizations to determine if anyone on any such list is attempting to open or maintain an account.
- Conduct, in certain instances, additional due diligence when accounts are opened for foreign persons, institutions or other clients.
The U.S. Department of the Treasury, U.S. Securities and Exchange Commission (the "SEC") and FINRA rules already require clients to provide most of this information.
If a client refuses to provide the information requested or a client's identity cannot be verified, ABG may not be able to establish or maintain a business relationship with such client. If such client has already established a relationship with ABG, we may have to terminate such relationship. If a client establishes a relationship with ABG and refuses to provide this information, we may be required to report such refusal to appropriate governmental authorities.
Notice to Canadian Clients Under National Instrument 31-103
Pursuant to the international dealer registration exemption in National Instrument 31-103, the Company is informing you of the following:
- ABG, LLC (the "Company") is not registered in Canada and is advising you, its client, in reliance upon an exemption from the dealer registration requirement under National Instrument 31-103.
- The below list contains ABG's agent for service of process for each province:
Ontario:
Borden Ladner Gervais LLP
Bay Adelaide Centre, East Tower
22 Adelaide Street
Toronto, ON M5H 4E3
Attention: Michael Taylor
Quebec:
Borden Ladner Gervais LLP
1000 Rue De la Gauchetière O#900
Montreal, Quebec H3B 5H4
Attention: Christian Faribault
British Columbia:
Borden Ladner Gervais LLP
Waterfront Centre, 200
Burrard St #1200
Vancouver, BC V7X 1T2
Attention: Jason Brooks
Clients may have some difficulty in enforcing any legal rights they may have against the Company because the Company is resident outside Canada and all or a substantial portion of its assets are situated outside Canada. The Company is not fully subject to the requirements of the Securities Act and the regulations thereunder concerning proficiency, capital, insurance, record keeping, segregation of funds and securities, statements of account and portfolio, and conflicts of interest.
November 2025