Privacy Policy

Gatekeeper Investment Advisers, LLC ("Gatekeeper," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you visit our website, request information, schedule a call, or otherwise interact with us. Gatekeeper is affiliated with Royal Fund Management, LLC, a registered investment adviser, and this policy applies jointly to information collected through this website.

This policy is designed to comply with the federal Gramm-Leach-Bliley Act (GLBA) and Regulation S-P, the SEC's rules governing investment advisers, the California Consumer Privacy Act as amended by the CPRA ("CCPA"), the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, and other applicable U.S. state privacy laws. If any provision of this policy conflicts with a law that applies to you, the applicable law controls.

Effective date: January 1, 2026.

We collect personal information you provide directly, information generated automatically when you use our website, and information from third parties such as service providers, plan recordkeepers, and public sources.

• Identifiers: name, email address, phone number, employer, job title, and mailing address.
• Commercial and plan information: information you volunteer about your 401(k) plan, plan size, participant count, current providers, and fiduciary structure.
• Internet activity: IP address, device and browser type, pages viewed, referring URLs, and timestamps collected through cookies and similar technologies.
• Communications: the content of forms, emails, chats, scheduled meetings, and voicemails you send us.
• Financial information you choose to share when engaging our advisory services, which becomes subject to the GLBA notice below.

We use personal information to:

• Respond to inquiries, schedule meetings, and provide requested materials.
• Evaluate plan eligibility and prepare fiduciary and investment recommendations.
• Operate, secure, and improve our website and services.
• Send transactional and, where permitted, educational communications you can opt out of at any time.
• Comply with legal, regulatory, tax, audit, and recordkeeping obligations, including those imposed by the SEC, state securities regulators, and the Department of Labor.
• Detect, prevent, and respond to fraud, abuse, and security incidents.

As an investment adviser, we are required under the Gramm-Leach-Bliley Act to explain how we handle nonpublic personal information about our clients and prospective clients.

Categories collected: information you give us on applications and forms (such as name, address, and financial goals), information about your transactions with us or others, and information from consumer reporting agencies when applicable.

Sharing: we do not sell nonpublic personal information. We share it only as permitted by law - for example, with custodians, recordkeepers, auditors, attorneys, and service providers who need it to perform services for us, or when required by regulators, subpoena, or court order.

Protection: we maintain physical, electronic, and procedural safeguards designed to protect nonpublic personal information, and we restrict access to employees and service providers who need it to serve you.

This notice continues to apply to former clients. You do not need to take any action to receive it; a copy is available on request.

We disclose personal information to:

• Affiliates, including Royal Fund Management, LLC, that support advisory services.
• Service providers acting on our behalf (hosting, analytics, email delivery, scheduling, CRM, e-signature, and captcha) under contracts that restrict their use of the information.
• Professional advisers such as auditors, attorneys, and compliance consultants.
• Regulators, self-regulatory organizations, and law enforcement when required by law, subpoena, or legal process, or to protect our rights, users, or the public.
• A successor entity in connection with a merger, acquisition, financing, or sale of assets, subject to this policy.

We use cookies, pixels, and similar technologies to operate the site, remember preferences, measure traffic, and improve content. For details and to manage your choices, see our Cookie Policy.

We advertise on LinkedIn. With your consent to analytics cookies, we load the LinkedIn Insight Tag to measure advertising performance and conversions, and we record the campaign tags (UTM parameters), landing page, and referring website associated with your visit so we can understand which campaigns generate inquiries. This information is used for measurement, not for selling personal information. If you decline analytics cookies, the LinkedIn Insight Tag is not loaded.

We honor Global Privacy Control (GPC) signals from your browser as an opt-out of sale or sharing of personal information under laws that recognize it.

Depending on where you live, you may have some or all of the following rights regarding personal information we hold about you:

• Right to know or access the categories and specific pieces of personal information collected, used, disclosed, and (where applicable) sold or shared.
• Right to correct inaccurate personal information.
• Right to delete personal information, subject to legal and regulatory retention requirements applicable to registered investment advisers.
• Right to opt out of the sale or sharing of personal information and of targeted advertising. We do not sell personal information or share it for cross-context behavioral advertising.
• Right to limit the use of sensitive personal information. We do not use sensitive personal information for purposes that require this limit under the CCPA.
• Right to non-discrimination for exercising your privacy rights.
• Right to appeal a denial of a rights request where required by state law.

Submit a request by emailing info@royalfundmanagement.com or calling 1-214-288-5018. We will verify your identity using information we already have on file before completing the request and will respond within the time required by applicable law. An authorized agent may submit a request with written proof of authorization.

We retain personal information only as long as necessary to fulfill the purposes described in this policy or as required by law. Records relating to advisory services are retained in accordance with SEC Rule 204-2 and other applicable regulations, generally for at least five years from the end of the fiscal year in which the record was created, the first two years in an easily accessible location.

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. No method of transmission or storage is completely secure; if we become aware of a security incident that affects your personal information, we will notify you as required by law.

This website is intended for a professional and adult audience and is not directed to children under 16. We do not knowingly collect personal information from children. If you believe a child has provided us information, contact us and we will delete it.

Our website links to third-party sites and services, including Calendly, Royal Fund Management, and 401(k) Maneuver. We are not responsible for their privacy practices; review their policies before providing information.

Our services are offered to businesses and residents in the United States. If you access the site from outside the U.S., you understand that your information will be transferred to, stored, and processed in the United States under U.S. law, which may differ from the law of your country.

We may update this Privacy Policy from time to time. Material changes will be posted here with a new effective date. Your continued use of the website after changes take effect constitutes acceptance of the revised policy.

Gatekeeper Investment Advisers, LLC

Email: info@royalfundmanagement.com

Phone: 1-214-288-5018