This notice is being provided to you in accordance with the Securities and Exchange Commission’s rule regarding the privacy of consumer financial information (“Regulation S-P”). Please take the time to read and understand the privacy policies and procedures that we have implemented to safeguard your nonpublic personal information. Nonpublic personal information means personally identifiable financial information and any list, description or other grouping of consumers that is derived using any personally identifiable financial information that is not publicly available. This is also information that we receive or develop during the course of our relationship. It includes (1) information you provide to us orally or on applications or other forms, (2) information we develop about you in the course of providing our services to you, such as the amount and type of your assets that we manage and transactions we place on your behalf, and (3) technical information we may develop and gather through your access to our website (e.g., identifying information communicated through “cookies” stored on your computer).
We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted or required by law, or as necessary to provide services to you. In accordance with Section 248.13 of Regulation S-P, we may disclose all of the information we collect, as described above, to certain nonaffiliated third parties such as attorneys, accountants, auditors and persons or entities that are assessing our compliance with industry standards. We enter into contractual agreements with all nonaffiliated third parties that prohibit such third parties from disclosing or using the information other than to carry out the purposes for which we disclose the information.
We restrict access to nonpublic personal information about you within Spectra Investment Management to only those who need the information in order to help us provide investment advisory services to you have access. It is our policy that, where we are not comfortable a service provider is already bound by duties of confidentiality (e.g., attorneys and auditors), we will require contractual assurances that they will maintain the confidentiality of any of your information they obtain. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.
If you have any questions about our practices with respect to your nonpublic personal information, you may contact us by email, telephone or regular mail.