Subprocessors

Updated 02.26.2026

This Subprocessors page explains what third-party vendors (subprocessors) may process personal information on behalf of SmartPath Advisors, LLC (“Frank,” “we,” “us,” or “our”), the types of data involved, and the purposes for which that data is processed. We maintain this list to support transparency and compliance with applicable privacy laws, including but not limited to the U.S. Gramm-Leach-Bliley Act (GLBA).

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For purposes of this page, “Personal Information” refers to any information that identifies or is reasonably capable of identifying an individual, including names, contact information, device identifiers, financial details, and other categories of information as described in our Privacy Policy.

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We may update this Subprocessors list from time to time as we add, modify, or remove subprocessors.

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Each subprocessor engaged by us is required to enter into a data protection agreement that incorporates appropriate technical, administrative, and organizational safeguards to protect Personal Information and restrict its use to performing services on our behalf.

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Subprocessors are contractually obligated to promptly notify us of any security incident affecting Personal Information, and we in turn comply with applicable privacy law obligations regarding breach notification.

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All subprocessor services are processed and stored inside the US.

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Note: Not all subprocessors are used for every user's experience and depend upon services provided.

Vendor
Type(s) of Personal Information Disclosed
Processing Category
Contact Information; Usage & Behavioral Data
Communications
Contact Information; Usage & Behavioral Data
Customer Support
Usage & Behavioral Data
Analytics & Performance Monitoring
Account & Financial Data; Personal Identifiers
Infrastructure & Hosting
Contact Information
Internal Collaboration & Communications
Account & Financial Data; Personal Identifiers; Usage & Behavioral Data
AI Processing / Model Hosting
Personal Identifiers; Account & Financial Data; Usage & Behavioral Data
Analytics
Account & Financial Data; Personal Identifiers; Usage & Behavioral Data
AI Processing / Model Hosting
Account & Financial Data; Contact Information (if applicable)
Financial Data Aggregation & Connectivity
Usage & Behavioral Data
Analytics & Performance Monitoring
Contact Information (Internal Only)
Internal Collaboration & Communications
Usage & Behavioral Data
Analytics & Performance Monitoring
Contact Information; Payment Information
Payment Processing

Type(s) of NPPI (Non-Public Personal Information)

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Personal Information Which May be Collected During Interaction with Frank (some items below may not be applicable and will not be collected):

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Account & Financial Data:

  • 529 accounts (account values, contribution amounts, holdings)
  • Account types
  • Credit score
  • Data from connected accounts (activity, amounts, holdings, rates, type) 
  • Date of birth
  • Debt (amount, history, terms, types, rates)
  • Dependent status (number of claimed persons)
  • Desired retirement age
  • Financial history and habits
  • FSA (account value and contribution amounts)
  • HSA (account value and contribution amounts)
  • Income / salary (specific number or range)
  • Income tax information
  • Living situation (rent or own; type of dwelling)
  • Marital status
  • Non-salary compensation (i.e., equity compensation)
  • Pension details
  • Real estate holdings and other assets
  • Savings and investment accounts of all types (account values, contribution amounts, holdings, performance, rates, types of accounts)
  • Tax filing status
  • Total assets (global amount)

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Contact Information:

  • Address
  • Email address
  • Name
  • Phone number

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Usage & Behavioral Data:

  • User Activity

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Personal Identifiers:

  • IP Address
  • Device identifiers
  • Cookie identifiers
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© 2025 All Rights Reserved. Frank is an AI-powered service provided by SmartPath Advisors, LLC, an investment adviser registered with the U.S. Securities and Exchange Commission (SEC). Registration with the Securities and Exchange Commission does not imply a certain level of skill or training. The advice, content, data, guidance, and/or information provided by Frank (collectively, Frank’s content) is based on user inputs, connected accounts, and Frank’s models and research. Frank’s content may contain errors and/or be outdated, and accordingly, Frank’s content should be carefully checked and verified by users prior to use or reliance. Any use or reliance on Frank’s content is at the user’s sole risk. We do not accept, assume, and/or agree to, and we expressly disclaim, any and all responsibility and/or liability for the use of, and/or reliance upon, Frank’s content. Without limiting the foregoing, Frank's content is not, and may not be construed as, legal and/or tax advice. Furthermore, all investing involves potential risk of loss, including the possible loss of principal. Past investment performance is not indicative of future investment performance.