Effective Date: March 30, 2026

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.

For Prospects who connect with an Advisor through Warmer, we maintain account and profile information on an ongoing basis in order to:

• Allow updates to personal and financial profiles;

• Re-run recommendations at the client’s request; and

• Prompt periodic reviews.

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.

Warmer retains nonpublic personal information for as long as a Prospect or Client maintains an account with us, or as reasonably necessary to provide our services, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements. When information is no longer required, it is securely deleted or de-identified in accordance with our data management policies.

4. What do you share with partners?

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

• We may share Client data with Advisors when Clients 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 and Microsoft Outlook.

  • Anthropic Claude and OpenAI API Platform, for language analysis and code generation.

• All partners handling sensitive data 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 remove my data?

• ​Yes.

• Prospects, Clients, and Advisors may request removal of data they have provided to Warmer by contacting support@getwarmer.com. 

• Warmer may retain data reasonably necessary to comply with security policies and applicable laws (such audit trails and data retention laws).

• Warmer may retain and display information derived from publicly available sources (such as regulatory filings). This information is not considered user-provided personal data (it is not PII).

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 remove data you shared with us 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