Privacy policy

FACTS – What do Lucia Capital Group (LCG); Lucia Securities, LLC (LSL); and Lucia Insurance Services, LLC (LIS) do with your personal information?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some, but not all, sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include the following:

  • Social Security number and income
  • Date of birth
  • Employment Information
  • Account balances, assets and investment experience
  • Investment objective, risk tolerance and transaction history

How?

All financial companies need to share customers’ personal information to conduct everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons LCG, LSL, and LIS choose to share; and whether you can limit this sharing.

Reasons we can share your personal information

Do LCG, LSL, and LIS

share?

Can you limit this sharing?

For our everyday business purposes – such as to process your transaction(s), maintain your account(s), apply for insurance coverage, respond to court orders and legal investigations, report to credit bureaus, or as permitted by law.

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 non-affiliates to market to you

NO

We don’t share

To Limit Our Sharing

Please note:  We do not share your information except as indicated in this notice.

Questions?

Call (800) 644-1150 or go to www.luciacap.com or www.luciasecurities.com

Who we are

Who is providing this notice?

LUCIA WEALTH SERVICES aka LUCIA CAPITAL GROUP; LUCIA SECURITIES, LLC; and LUCIA INSURANCE SERVICES

What we do

How do LCG, LSL, and LIS protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We employ physical, electronic, and procedural safeguards for the protection of the personal information we collect about you.

How do LCG, LSL, and LIS collect my personal information?

We collect your personal information, for example, when you:

  •   Open an account or seek advice about your investments
  •    Direct us to buy or sell securities
  •    Enter into an investment advisory contract or tell us about your investment or retirement portfolio
  •    Apply for life, health, or long-term care insurance coverage

We also collect your personal information from others, such as credit bureaus and other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only:

  •  Sharing for affiliates’ everyday business purposes – information about your creditworthiness
  • Sharing for affiliates to market to you
  • Sharing for non-affiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See Other Important Information below for more on your rights under state law.

What if I limit sharing for an account I hold jointly with someone else?

Your choices will apply to everyone on your account unless you tell us otherwise.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial or nonfinancial companies.

  • Lucia Capital Group
  • Lucia Wealth Services aka Lucia Capital Group
  • Lucia Management Company
  • Lucia Licensing
  • LCM Investment Management
  • Lucia Securities, LLC
  • Lucia Insurance Services
  • Validus Investment Advisors

Non-affiliates

Companies not related by common ownership or control. They can be financial or nonfinancial companies:

  • Non-affiliates we may share information with can include clearing agents, investment advisor firms, mutual fund companies, insurance companies, other product sponsor and technology companies.

Joint Marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

  • LCG, LSL, and LIS do not jointly market with non-affiliates.

Other Important Information

California residents must consent to sharing their information with nonaffiliated third parties prior to that information being shared.

BUSINESS CONTINUITY STATEMENT

Lucia Securities, LLC is committed to protecting our employees, our clients, and client assets at all times, including in times of emergency. As part of this commitment, and in compliance with industry regulations, the Firm maintains a business continuity plan. The business continuity plan outlines how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information.
Contacting Us – If after a significant business disruption you cannot contact us as you usually do at 800-644-1150, you should call our alternative numbers at 619-497-5555 or 480-999-5177 or attempt to fax us at 858-519-8931. If you cannot access us through any of those means, you should continue to contact your financial advisor via his or her cell phone or check back on our website or Crisis Communication Hotline often (as that may be our only means of communication). Our website is www.luciasecurities.com or www.luciacap.com and our Crisis Communication Hotline is 858-999-3077. For accounts held outside our Clearing Firm, such as variable annuity contracts or mutual fund accounts, please contact the insurance or fund company directly at the number provided on your account statement(s).
Our Business Continuity Plan – We plan to quickly recover and resume business operations after a significant business disruption and will respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible given the scope and severity of the significant business disruption.
Our business continuity plan addresses data back-up and recovery; all mission-critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; an alternate physical location of employees; critical supplier, contractor, bank, and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.
Our Clearing Firm, RBC Correspondent Services (“RBC CS”), backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our Clearing Firm that its objective is to restore its own operations, be able to complete existing transactions, and accept new transactions and payments within the same business day. Your orders and requests for funds and securities could be delayed during this period. Please be advised that while we have plans in place, we cannot guarantee to recover as quickly as outlined above under all circumstances. Our recovery time may be negatively impacted by the availability of third parties and/or circumstances beyond our control.
Varying Disruptions – Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where our firm are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within the same business day. If a significant business disruption were to occur, we would notify you through our website www.luciasecurities.com, via our Crisis Communication Hotline at 858-999-3077, or, if able, by sending you an alternate phone number and/or email. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customers prompt access to their funds and securities.

ROUTING ORDERS

Lucia Securities, LLC (LSL) may route client orders for execution to our clearing firm, RBC Correspondent Services (“RBC CS”); market centers; or by using automated order entry systems on primary exchanges. These market centers may include dealers who are registered market makers in securities. LSL may be compensated for routing orders to dealers or may receive credits for exchange transaction fees from using automated order entry systems. However, LSL does not receive remuneration for directing equity order flow at this time. Order routing decisions may be based on the size of the order, an opportunity for price improvement, and/or quality of order executions. All orders are intended to be executed in compliance with best execution.
RBC CS has provided information pursuant to SEC Rule 11AC1-3 and Rule 606 (formerly known as Rule 11AC1-6) that requires firms to make publicly available quarterly reports on the firm’s order routing practices. The report provides information on the routing of “non-directed orders” which is generally defined as any order that the client has not specifically instructed to be routed to a particular venue for execution.
For these non-directed orders, RBC CS has selected the execution venue on behalf of its clients.
The report is divided into four sections: one for securities listed on the New York Stock Exchange, one for securities listed on The Nasdaq Stock Market, one for securities listed on the American Stock Exchange or regional exchanges, and one for exchange-listed options.
For each section, this report identifies the venues most often selected by RBC CS, sets forth the percentage of various types of orders routed to the venues, and discusses RBC CS “Payment for Order Flow and Routing of Customer Order Disclosure Statement”.
LSL will provide the order routing details upon written request for orders executed six months prior. To obtain a copy of our quarterly routing report, please contact the Lucia Securities Trading Department at 800-644-1150.
The firm’s order-handling statistics are available at http://external.s3.com/rule606/rbcwm/correspondentsvcs/. For historical information, visit http://www.tagaudit.com/do/display?page=Rule606::Report.

PROTECTING YOUR ASSETS

Securities in your account are protected for up to $500,000 (cash up to $250,000) by the Securities Investor Protection Corporation (SIPC). Our Clearing Firm, RBC Capital Markets, LLC, has purchased an additional policy covering up to $99.5 million per SIPC qualified account, subject to a maximum aggregate for RBC Capital Markets, LLC of $400 million. This protection applies to the physical loss or destruction of your securities; it does not apply to any decline in the market value of your securities. Other investments shown on your statement but not held at RBC Capital Markets, LLC may not be protected by SIPC or private insurance policies purchased by RBC Capital Markets, LLC. For more details, please talk to your financial advisor, call SIPC at (202) 371-8300 for a brochure, or visit www.sipc.org.

FURTHER DISCLOSURES

CONFLICTS OF INTEREST: While we strive to put our clients’ interests before our own, LSL’s interest may not always be the same as

yours. Please ask us questions to make sure you understand your rights and our obligations to you, including the extent of our obligations to disclose conflicts of interest. We are paid by you and, sometimes, we receive compensation from mutual fund families, variable annuity issuers, and alternative investment companies that are available to our brokerage and advisory customers. These payments are made in connection with programs that support our marketing and salesforce education and training efforts, such as our annual national sales and education conference and other seminars. In some cases, sponsors may pay additional marketing payments to LSL and/or your financial advisor to cover fees to attend conferences or reimbursement of expenses for marketing their products through workshops, seminars, and other forms of advertising. We believe that these payments do not compromise the advice your financial advisor gives you. However, if you have concerns about any potential conflict of interest, please contact LSL or your financial advisor directly.

LSL is under common ownership with Lucia Wealth Services (aka Lucia Capital Group) an Investment Advisor registered with the SEC. You may also be a client of or offered services or programs sponsored by Lucia Capital Group. For additional information about these programs, please request a copy of the Lucia Capital Group ADV Part 2 disclosure brochure.

LEVERAGED/INVERSE LEVERAGED ETF’S: Client acknowledges and understands that if they have executed a signed Lucia Wealth Advisory Program Agreement, Lucia Capital Group (“LCG”) has investment discretion and will manage accounts covered by the agreement as set forth by the terms and conditions of the agreement between the Model Portfolio Advisor and LCG. LCG may invest a portion of your account in leveraged or inverse leveraged ETFs.  Client understands that leveraged and inverse leveraged ETFs are speculative investments that carry significant risks. These risks include but are not limited to significant volatility providing the potential for significant losses and use of leverage and derivative instruments to achieve stated investment objectives. Most leveraged and inverse funds seek daily target returns. Due to the effect of compounding, the return if invested for a period different than one trading day may vary significantly from the fund’s stated goal. Leveraged and inverse leveraged ETFs may have higher operating expenses and fees as they rebalance their portfolios on a daily basis.

Client understands that leveraged and inverse leveraged ETFs should be actively monitored on a daily basis and are typically not appropriate for a buy and hold strategy.

FINRA INFORMATION: In accordance with FINRA Rule 2267, we provide the following information: The FINRA Public Disclosure Hotline (BrokerCheck) is (800) 289-9999. FINRA’s website is www.finra.org. You may obtain a copy of an investor brochure that includes information describing FINRA BrokerCheck by calling the above number or visiting FINRA’s website.

CLIENT COMMENTS AND CONCERNS: Client service is our priority. If you have general comments or concerns, please write a letter to us at Lucia Securities, LLC, Attn.: Compliance Dept., 13520 Evening Creek Dr. N., Suite 300, San Diego, CA 92128 or call our office at 800- 644-1150 and ask to speak to the compliance department.