Maintaining the confidentiality of client personal financial information is very important to Strategic Global Advisors, LLC (“SGA”). SGA may collect several types of nonpublic personal information about clients or investors, including:
- Information from forms that clients may fill out and send to SGA in connection with SGA’s services (such as name, address, and social security number).
- Information a client may give SGA orally.
- Information about the amount clients have invested with SGA or in a private investment fund (such as initial investment and any additions to and withdrawals from a capital account).
- Information about any bank account clients may use for transfers between a bank account and an SGA’s managed accounts or capital account of a private investment fund.
SGA does not sell or disclose client personal information to anyone except as permitted or required by law. Information collected may be shared with the independent auditors in the course of the annual audit of SGA. SGA may also share this information with SGA’s legal counsel and with regulators as it deems appropriate. SGA may disclose information about a client at the client’s written request (for example, by sending duplicate account statements to someone designated by the client or investor), or as otherwise permitted or required by law. Finally, and upon prior written consent of the client, SGA may disclose the client’s name in its marketing materials.
Within SGA, access to information about clients is restricted to those employees who need to know the information to service client accounts. SGA’s employees are trained to follow its procedures to protect client privacy and are instructed to access information about clients only when they have a business reason to obtain it.