Ogolvy Wealth, LLC d/b/a Field Wealth Intelligence
Effective Date: May 27, 2026
This Privacy Policy describes how Ogolvy Wealth, LLC d/b/a Field Wealth Intelligence ("Field," "we," "us," or "our") collects, uses, discloses, and protects information in connection with the services we provide to our business clients and the operation of our Websites at fieldwealth.ai, bridgeft.com, and precept.sh (the "Websites"). Field is a business-to-business ("B2B") technology company that provides data normalization and other services to Registered Investment Advisers ("RIAs") and Asset Managers. Field does not provide services directly to individual consumers. Rather, Field provides a data infrastructure for the private wealth ecosystem by ingesting, normalizing, and enriching data to help RIAs and Asset Managers better visualize potential wealth management solutions for clients.
Field is not a registered investment adviser. Field does not provide investment advisory, brokerage, custody, portfolio management, or individualized financial-planning services to individual consumers. Field operates as a service provider to RIAs and Asset Managers, providing technology infrastructure for data normalization and, when commercially available, a platform and network for aggregated, deidentified, or pseudonymized data exchange.
Field processes Nonpublic Personal Information ("NPI") and other personal information as a service provider to financial-institution clients and contractually supports those clients' privacy, safeguarding, disposal, incident-response, and notice obligations under the Gramm-Leach-Bliley Act ("GLBA") and Regulation S-P, where applicable. Field processes NPI only for the limited purposes authorized by the applicable client agreement and client instructions. To the extent a client relies on a GLBA/Regulation S-P service-provider exception or other applicable exception, Field's contracts are intended to restrict Field from using or disclosing NPI except as necessary to provide the contracted services, as otherwise permitted by law, or as directed by the client. Field is also subject to state privacy and data protection laws, where applicable.
Field processes the following categories of information in connection with its services:
NPI and Personally Identifiable Information (PII): At the household and individual account levels, Field processes NPI/PII that is regulated under GLBA and applicable state laws. This may include financial account data, portfolio holdings, transaction histories, account balances, beneficiary information, household relationships, and other information associated with individual clients and households of our RIA clients.
Confidential Business Information: At the RIA firm level and individual advisor level, Field processes confidential business information that, while not constituting PII or NPI in all cases, is treated as proprietary to the RIA. This includes firm-level aggregates, advisor-level portfolio summaries, business performance metrics, and related operational information. Advisor-level and firm-level data is not treated as personal information or NPI where it cannot reasonably be linked to identifiable individuals, households, or accounts.
Business Contact Information: Field collects business contact information from representatives of its RIA and Asset Manager clients, including names, business email addresses, telephone numbers, job titles, employer names, and professional account credentials, for purposes of managing the client relationship and administering access to the services.
Information Collected Automatically: When you visit or interact with our Websites, we may use a variety of technologies to collect information about your usage. This may include your IP address, device identifier, browsing or search history, preference information, account settings (including any default preferences), and other information regarding your interactions with and use of our Websites. We may also collect your non-precise geolocation derived from your IP address. We use this information to analyze how users interact with our Websites, secure and operate the Websites, and improve the user experience.
Field's data architecture recognizes a four-tier structure from RIA entity down to individual account:
Field ingests data from multiple data sources, including custodial, customer relationship management, and portfolio management platforms used by its RIA clients. All data is received pursuant to contractual data permissions granted by the RIA client, including the applicable client agreement, data processing addendum, data-permission schedule, integration permissions, or other written instructions.
Field uses information collected from and on behalf of its RIA clients for the following purposes:
Data Normalization Services: Field ingests and normalizes data across multiple data sources for RIAs and Asset Managers through schema mapping, data cleansing, validation, enrichment, and delivery via a unified API or flat file delivery. The purpose is to provide RIAs and Asset Managers with one normalized data feed from any data source, enriched, validated, and delivered in a standardized format.
Other Services: When commercially available, Field may facilitate a data exchange connecting RIAs to Asset Managers. Field does not disclose identifiable household-level or account-level NPI to Asset Managers through the data network unless expressly authorized by the applicable RIA client and permitted by law. The data network provides aggregated, deidentified, or pseudonymized data analytics and business intelligence subject to contractual restrictions, technical safeguards, minimum cohort thresholds where appropriate, and prohibitions on reidentification and onward disclosure.
Product Development and Testing: Field may use deidentified or permissioned data from RIAs to build, test, validate, and improve its products.
Service Administration: Field uses business contact information to manage client relationships, administer user accounts, provide customer support, fulfill contractual obligations, process billing and financial administration, comply with legal obligations, and communicate regarding service updates.
Field distinguishes among pseudonymized data, deidentified data, and aggregated analytics. Pseudonymized data means direct identifiers are removed or replaced, but Field may retain the technical ability to reidentify the data. Deidentified data means data that Field has processed and maintains using reasonable measures designed to prevent association with an individual, household, or account, and Field commits not to reidentify such data except as permitted by law for validation, security, service provision to RIAs or compliance purposes. Aggregated analytics means outputs compiled across multiple records and, where appropriate, subject to minimum cohort thresholds or other controls designed to reduce reidentification risk.
For its data network, when commercially available, Field removes or obscures direct identifiers before data is made available to Asset Managers and applies contractual and technical controls designed to prevent Asset Managers from identifying, attempting to identify, or contacting individual consumers, households, or account holders, or advisors except as expressly authorized by the applicable RIA client. Field may employ techniques such as k-anonymity, differential privacy, suppression, generalization, and reidentification-risk testing where appropriate; however, no deidentification technique can eliminate all risk in every circumstance.
Field may disclose information in the following circumstances:
To Asset Managers As Part of the Data Network: Aggregated, deidentified, or pseudonymized analytics only, subject to contractual restrictions and controls designed to prevent reidentification. Field does not disclose identifiable household-level or account-level NPI to Asset Managers through its data network unless expressly authorized by the applicable RIA client and permitted by law.
To Service Providers: Field may engage sub-processors and technology vendors who assist in providing our services, including IT providers, internet service providers, web hosting providers, data analytics providers, and companies that provide business support services or financial administration, subject to written contracts that impose confidentiality, security, privacy, incident-notification, data-use, and flow-down obligations appropriate to the information processed. Where required by contract, Field will maintain a subprocessor list and provide notice of material subprocessor changes.
To Professional Consultants: Field may disclose information to accountants, lawyers, financial advisors, and audit firms for legal, compliance, and accounting purposes, subject to professional or contractual confidentiality obligations.
As Required by Law: Field may disclose information where required by applicable federal or state law, regulation, legal process, or governmental request, including to law enforcement or government agencies to comply with a subpoena or legal requirements for legal, security, or safety purposes.
In Connection with a Corporate Transaction: Field may disclose information if we, or some or all of our assets, are acquired by another entity, including through a sale in connection with bankruptcy or other forms of corporate change, subject to confidentiality protections and applicable contractual restrictions.
With Client Consent: Field may disclose information where any individual has provided explicit permission for such disclosure, including directly to Field or indirectly through an RIA or other third party.
Field operates on a principle of transparent contracting for permissioned data. Field contracts explicitly with RIA clients for the scope of data processing authorized, including whether data may be used for its data network or other services. Field may use client data for product development, provision of services (including its data network services), benchmarking, analytics, or other secondary uses in accordance with applicable law. Unless the contract provides otherwise, an RIA client may disable or decline participation in the data network for its data.
Field acknowledges that individual consumers whose NPI or PII is processed by Field may have rights under applicable state privacy laws, including but not limited to rights of access, deletion, correction, and opt-out of certain data sharing.
Because Field does not maintain a direct relationship with the individual consumers whose data it processes, Field operates as follows with respect to data subject access requests ("DSARs"):
Field implements and maintains administrative, technical, and physical safeguards designed to protect information from unauthorized access, disclosure, alteration, or destruction and to support RIA clients' privacy and security obligations. These safeguards include, but are not limited to:
However, no transmission over the Internet or any network can be guaranteed to be 100% secure. Any transmission of information to Field over the Internet is at your own risk.
Field maintains an incident-response program designed to detect, respond to, and recover from unauthorized access to or use of client data. Field will notify affected RIA clients without undue delay and in accordance with applicable contractual requirements. For customer-information systems maintained by Field as a service provider to a covered institution under Regulation S-P, Field will notify the covered institution within 72 hours after becoming aware of a breach in security resulting in unauthorized access to such covered institution's NPI or confidential information, unless Field's customers have provided written notification that a different legally permitted standard applies. Field will reasonably cooperate with affected RIA clients' investigations, regulatory assessments, consumer notifications, and remediation activities subject to the terms and conditions agreed to between the parties.
Field retains information processed on behalf of its RIA clients for as long as necessary to provide the services, comply with legal and regulatory obligations, resolve disputes, enforce agreements, maintain security and audit logs, or as directed by the RIA client pursuant to our contractual relationship. Upon termination of a client relationship, Field will return or destroy client data in accordance with the terms of the applicable service agreement, subject to backup-retention cycles, legal holds, security/audit logging, and other legally permitted exceptions. Deidentified or aggregated analytics may be retained after termination where permitted by the applicable agreement and law and where they are not reasonably linkable to a particular individual, household, account, or RIA client.
Field may use the following tracking technologies on its Websites:
Cookies, which are short text files, may be downloaded to your computer during the course of your visit to our Websites. You are not obliged to accept a cookie that we send to you, and you can modify your browser so that it will not accept cookies.
Pixels, web beacons, and tags, which are types of code or transparent graphics that contain a unique identifier, may also be used. These technologies provide analytical information about the user experience and help us customize our communications. In contrast to cookies, which are stored on a user's computer hard drive, pixels, web beacons, and tags are embedded invisibly on web pages.
You may accept or decline cookies. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Websites. You must take these steps on each browser or device that you use. If you replace, change, or upgrade your browser or device, or delete your cookies, you may need to use these opt-out tools again. Please refer to your browser's help menu for information on how to manage cookies.
Web browsers and other technologies you may use to access our Websites may include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. We do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.
Our Websites and services are not directed to children under 18 years of age, and we do not knowingly collect any personal information of children under 18 years of age. If you believe a child under 18 years of age has provided us with personal information, please contact us using the contact information provided below.
While browsing our Websites, you may encounter and choose to access websites or online services operated by third parties by clicking on hypertext links or icons. These websites may collect data or personal information about you and your online activities. We do not control and are not responsible for what these other parties do in connection with their websites or online services, or how they handle your personal information. We encourage you to review the privacy policies of any third-party websites you visit.
To the extent Field is subject to the California Consumer Privacy Act as amended by the California Privacy Rights Act, Field acts as a "service provider" or "contractor" as defined under that law when processing personal information on behalf of its clients (the "businesses") pursuant to written contracts that restrict Field's use of personal information to the purposes specified in those contracts. Field does not sell personal information. Field does not share personal information for cross-context behavioral advertising purposes. Field's client contracts are intended to prohibit Field from selling or sharing client personal information, using it outside the limited and specified business purposes, retaining, using, or disclosing it outside the direct business relationship except as permitted by law and contract, combining it except as permitted by law and contract, and engaging subprocessors without appropriate flow-down obligations.
Field complies with applicable state privacy laws as they become effective. In each case, Field's role as a processor, service provider, or contractor to its RIA clients governs the nature of its obligations under those laws, and Field processes personal information in accordance with the applicable client agreement, data processing addendum, and client instructions. This Policy does not create consumer rights where a law does not apply or where an exemption, including an exemption for information subject to GLBA, is available.
Field reserves the right to update or modify this Privacy Policy at any time. When we make material changes, we will notify our clients through our standard communication channels and update the "Effective Date" at the top of this document.
If you have questions about this Privacy Policy or our data practices, please contact us at:
Ogolvy Wealth, LLC d/b/a Field Wealth Intelligence
Attn: Privacy Inquiries
270 Madison Ave, Suite 301
New York, NY 10016
Privacy@fieldwealth.ai
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