Financial Emergence LLC recognizes and respects the privacy of our customers and are committed to safeguarding our customers’ nonpublic personal information. The below policies describe the types of information collected from investment management clients, and the circumstances in which that information will be disclosed by Financial Emergence to third parties. The provisions of the following disclosure apply to former customers as well as current customers. For purposes of this disclosure, the terms “customer” or “customers” includes both separately managed account clients of Financial Emergence and parties that provided Financial Emergence with nonpublic personal information but did not make an investment.
Information Collected
Financial Emergence collects nonpublic personal information about customers for business purposes in connection with investment management operations. Such information is collected from the following sources:
- Advisory Agreement, Advisory Questionnaire, Anti-Money Laundering Identification, Account Documents, and Other Forms, which may include information such as your name, address, social security number, income information, net worth, investment experience, educational background and banking information;
- Account History, such as information regarding the assets in your account and account transactions, including the parties to a transaction, the positions held or sold, and pricing; and
- Correspondence, written, telephonic or electronic between investors, Financial Emergence and/or any service providers for Financial Emergence, or the Customer’s brokerage accounts.
“Nonpublic personal information” is nonpublic information about investors that is obtained in connection with providing a financial product or service for Customers.
Information Disclosure to Third Parties
In the normal course of business, all of the nonpublic personal information collected about Customers may be shared with other persons who provide services in connection with advised accounts (including brokers, administrators, custodians, accountants or attorneys, as well as any other service providers for its accounts).
Financial Emergence may also disclose personal information with non-affiliated entities and regulatory authorities as permitted or required by applicable law. For example, Financial Emergence may disclose such information to cooperate with regulatory authorities and law enforcement agencies and as necessary to protect its and its Customers’ rights and assets. Financial Emergence does not sell any personal information about the Customers to any third party.
Protecting Confidentiality and Security
Financial Emergence maintains physical, electronic, and procedural safeguards to protect the nonpublic personal information about its strategies and Customers. It treats this information in a confidential manner. Financial Emergence restricts access to nonpublic information to Employees who have an appropriate reason to access it. Financial Emergence requires third parties with whom information is shared to:
- maintain policies and procedures designed to assure only appropriate access to, and use of information about, Financial Emergence’s Customers; and
- maintain physical, electronic and procedural safeguards that comply with federal standards to guard nonpublic information.
Additional Information
Financial Emergence maintains detailed policies addressing, among other things, Privacy and Information Security Protection, Cybersecurity, Information Stored in Hard Copy Formats, Privacy Breach and Cybersecurity Incident Response, and Training. Additional details are available upon request.