Last updated: 2026-05-24
Privacy notice
ClientGen, LLC (“ClientGen,” “we,” “us”) provides done-for-you marketing operations to independent financial advisors and the broker-dealers they affiliate with. This notice describes what personal information we collect about advisors and the prospects/clients those advisors market to, how we use it, and the choices each party has.
1. Scope
This notice covers the data ClientGen processes on behalf of advisors and broker-dealers, as well as data we collect directly from users of clientgen.app, app.clientgen.app, and the personalized landing pages we render at clientgen.app/for/{token}.
ClientGen does not handle end-investor account numbers, balances, Social Security numbers, government identifiers, or custodial data. Those remain with the advisor’s broker-dealer and custodian.
2. What we collect
- Advisor profile: name, firm, broker-dealer affiliation, geographic market, niche, professional credentials, brand assets pulled from the advisor's own website.
- Lead/prospect data sourced through the advisor's authorized data providers: name, business contact information, employer, public firmographic data, estimated investable-assets band, engagement signals (opens, clicks, replies).
- Marketing performance: aggregated impressions, click-throughs, replies, meeting bookings.
- Account + usage data when an advisor signs in to app.clientgen.app: email, authentication tokens, audit logs of agent runs taken on the advisor's behalf.
3. How we use it
- Operate the advisor's marketing — generate creative in the advisor's voice, schedule + deploy on the advisor's behalf, report weekly outcomes.
- Pre-flight every regulated asset against the broker-dealer's advertising rule pack before any human approval (FINRA 2210 / SEC Marketing Rule).
- Maintain an immutable audit trail of agent activity for SEC 17a-4 / FINRA 4511 recordkeeping.
- Communicate with the advisor about the service and surface signals (hot replies, performance shifts) that need their attention.
4. How we protect it
- Encryption at rest (AES-256) and in transit (TLS 1.3 minimum). Documented in our Written Information Security Policy.
- Strict tenant isolation: per-advisor row-level data separation, query-level enforcement, no cross-tenant model context.
- Append-only audit ledger for every agent run; database triggers prevent updates or deletes.
- Least-privilege access for ClientGen workforce; SSO with phishing-resistant MFA where applicable.
- Recurring cyber-compliance program (training, phishing simulations, asset inventories, incident response).
5. Your choices
Advisors may at any time request: a copy of the data we hold on you, correction of inaccurate data, deletion of data not subject to recordkeeping obligations, withdrawal from any marketing cadence we operate on your behalf. Contact [email protected].
Prospects + clients reached by an advisor’s marketing through ClientGen may opt out using the unsubscribe link in any email, the LinkedIn block/report features, or by contacting the advisor directly. We honor opt-outs across every channel ClientGen operates for that advisor; we don’t re-route opt-outs into a different cadence.
6. Data we don’t share
We do not sell personal information. We do not provide third-party advertising. Sub-processors are listed in our Due Diligence Questionnaire (available to broker-dealers on request) and limited to: Cloudflare (infrastructure), Neon (database), Anthropic (model inference), Resend (transactional email), Stripe (billing), and the ad platforms an individual advisor authorizes us to push to.
7. Retention
Recordkeeping-bound data (advisor-facing creative, compliance reviews, audit logs) is retained for seven years or longer where required by an advisor’s broker-dealer. Lead data is retained while the advisor is an active customer plus 90 days. Backup retention is 30 days.
8. Contact
ClientGen, LLC
[email protected]
For security disclosures: [email protected]
This notice is published for transparency. Counsel review pending; please treat as draft pending the next revision.