This Client Privacy Notice is from Clear Capital Management LP, a registered investment advisor firm in the business of providing investment advisory services to clients. We are committed to safeguarding the confidential information of our clients. We hold all personal information provided to our firm in strictest confidence. Except as required or permitted by law, we do not share confidential information about you with nonaffiliated third parties. In the unlikely event there were to be a change in this fundamental policy that would permit or require additional disclosures of your confidential information, we will provide written notice to you, and you will be given an opportunity to direct us as to whether such disclosure is permissible.
We collect and develop personal information about you, and some of that information is non-public personal information (“Client Information”). As an investment advisor, we collect and develop Client Information about you in order to provide investment advisory services. Client Information we collect includes:
• This Client Information may include personal and household information such as income, investment objectives, financial goals, statements of account, and other records concerning your financial condition and assets.
• Information developed as part of investment advisory services.
• Information concerning investment advisory account transactions.
We restrict access to Client Information to those representatives and employees who need the information to perform their job responsibilities within our firm. We maintain agreements, as well as physical, electronic and procedural securities measures that comply with federal regulations to safeguard Client Information about you.
To administer, manage and service client accounts, process transactions and provide related services to your accounts, it is necessary for us to provide access to Client Information within our firm and to non-affiliated companies such as other investment advisors, broker-dealers and custodians. We may also provide Client Information outside of our firm as permitted by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas.
If the account with our firm is closed, we will continue to operate in accordance with the principles stated in the Client Privacy Notice.
In November 1999, Congress enacted the Gramm-Leach-Bliley Act (“GLBA”). The GLBA requires certain financial institutions, including broker-dealers and investment advisors, to protect the privacy of Customer Information. To the extent a financial institution discloses Client Information to non-affiliated third parties other than as permitted or required by law, clients must be given the opportunity and means to opt out (or prevent) such disclosure. Please note that we do not disclose Client Information to non-affiliated third parties except as permitted or required by law (e.g., disclosures to service your account or to respond to subpoenas).