The relationship between Spouting Rock and our clients is our most important asset. We strive to maintain your trust and confidence in our firm, an essential aspect of which is our commitment to protect the confidentiality, integrity and security of your non-public personal information. As we believe that all of our clients value their privacy, we do not disclose your non-public personal information to anyone unless it is required by law, at your direction, or is necessary to provide you with our services. We do not sell your non-public personal information to anyone.
Personal Information That We Collect, Maintain, and Communicate
We collect and maintain your non-public personal information, so we can provide investment management and/or tax preparation services to you. The types and categories of information we collect and maintain about you include:
- Information we receive from you to open an account or provide investment or tax services to you (such as your date of birth, social security number, address, telephone number, and financial information);
- Information about your transactions with us, our affiliates, or others to service your account (such as trade tickets and account statements);
- Information that we receive from third parties with respect to your account (such as trade confirmations from brokerage firms).
- Information provided to us by authorized parties acting on behalf of our clients such as accountants, attorneys, and investment consultants.
In order for us to provide investment management and tax services to you, we may disclose the non-public personal information that we collect and maintain in very limited instances, which includes:
- Disclosures that are authorized or requested by you;
- Disclosures that are required by law (for example, to cooperate with regulators or law enforcement authorities);
- Disclosures to companies that perform services on our behalf (such as data processors that provide investment accounting and reporting services, or otherwise assist us in delivering services to our clients) subject to agreements that prohibit such companies from disclosing or using the information other than for the services required or as permitted by law;
- Disclosures to companies as otherwise permitted by law, including those necessary to service your account (such as providing account information to brokers or custodians).
How We Protect Your Personal Information
To fulfill our privacy commitment, we have instituted firm-wide practices to safeguard the information that we maintain about you. These include:
- Maintaining physical, electronic and procedural safeguards that comply with federal regulations to guard your non-public personal information;
- Limiting access to non-public personal information to employees and third parties that are necessary or appropriate to provide services to you;
- Requiring third parties that perform services to us to agree by contract to keep your information strictly confidential;
- Protecting information of our former clients to the same extent as our current clients.