Effective Date: October 30, 2025

Welcome to Warmer! 

We are committed to protecting your personal information as a user of Warmer. Please read this policy to understand our practices on collecting, using and safeguarding your data.

1. What information does Warmer collect?

• Prospect and Client Information: Personal identifiers, household information, financial profile, preferences, and communications. These are “nonpublic personal information” as defined by Regulation S-P. References to Prospects and Clients mean ‘consumers’ and ‘customers’ for the purposes of Regulation S-P.

• Advisor Information: Advisor and Advisory firm details, user names, and other profile information.

• Usage Data: Interactions with our services including website/email/app activity, product feedback, device information, and generated client insights.

• Synced Firm Data: Information from advisor tech integrations, such as:

  • CRM: Client list with email addresses, profiles, tasks, and notes.

  • Email: Emails sent from or to active clients’ email addresses.

  • Calendar: Events associated with active clients’ email addresses.

  • Documents (e.g., notes, transcripts): Specific drives, folders and/or files determined to be associated with an active client

• ​Communication Data: Communications with us such as sales and customer support inquiries.

• Payment Information: Billing details for processing payments.

2. How do we use your information?

• Advisor matching: Prospect and Advisor data are used to match Prospects to Advisors, maintain referral records, improve matching quality, and communicate required disclosures.

• Service improvement: Analyze usage data for product development and user experience opportunities.

• Quality control: Compare generated client insights to source data in order to improve insight accuracy and quality.

• Account management: Provide updates, conduct billing, or respond to inquiries.

• Security: Detect and prevent fraud and malicious activities.

3. How is data access managed at Warmer?

• Employees are provisioned access only to information appropriate to their function.

• Production systems are accessible only to authorized employees directly involved in product and development.

• Customer data – including client and advisor information, communication data, and payment information – are only accessible by authorized employees responsible for development, service, and operations.

• Safeguards referenced in this Policy are implemented through Warmer’s Compliance Manual and supporting information-security policies.

4. What do you share with partners?

• We do not sell advisor or client information to third parties.

• We may share your data with Advisors when you choose to connect with them. Firms receiving referral information are separate fiduciaries subject to Reg S-P; Warmer requires them to have up-to-date security and privacy policies. Their use of client data is governed by their own privacy policies, not by Warmer.

• We share data with third parties responsible for helping us operate and improve our service, including:

  • Amazon Web Services and Heroku, for data storage and computing.

  • Merge.dev, for connections to Box, Dropbox, Google Drive, Hubspot, Microsoft OneDrive, Microsoft SharePoint, and Salesforce.

  • Nylas, for connections to Gmail, Microsoft Outlook, Hotmail, and Yahoo Mail.

  • OpenAI API Platform and ChatGPT Enterprise, for language analysis and generation.

• All data vendors are SOC2 certified.

5. Is my data being used to train ChatGPT or any other generalized AI/ML models?

• No.

• Warmer will not use client or advisor data to develop, improve or train a generalized AI/ML model. This includes data shared directly with Warmer and also via integration with partners, such as Google Workspace APIs.

• OpenAI API Platform and ChatGPT Enterprise are not permitted to use information shared by Warmer in order to train their models (OpenAI Enterprise Privacy Policy).

• For the avoidance of doubt, the applicable OpenAI privacy standards are both distinct from and stricter than those that govern OpenAI’s publicly-available version of ChatGPT.

6. How do you keep my data secure?

• All data is encrypted at rest and in transit.

• Data and employees are based in the United States.

• Company devices and systems are protected by safeguards including automatic access provisioning/deprovisioning and mandatory two-factor authentication (wherever available).

• Credentials to third-party systems (such as usernames and passwords) are not stored in Warmer data.

7. Do I have the right to delete my data?

• Yes.

• Prospects, Clients, and Advisors may request deletion of their personal data at support@getwarmer.com.

• We will delete all personal data, and make reasonable efforts to delete any associated data.

• Publicly available information (not PII) may be retained by Warmer (e.g., SEC data on advisory firms)

8. That’s a lot. What should I remember?

• Your data privacy is important to us.

• Your data is encrypted at all times.

• Your data is not being used to train ChatGPT or other LLMs.

• We will delete your personal or firm data upon request.

9. Changes to Policy

We may update this Privacy Policy from time to time. We will notify you (at least annually) of any significant changes and post the current Policy on our website.

Relationships are everything, and your trust is important to us. If you have any questions about these Terms, please contact us at support@getwarmer.com.

Warmer Holdings Inc.
33 Irving Place, 3rd Floor
New York, NY 10003