Effective: August 26, 2010
Our Commitment to You
7Twelve Advisors, LLC (“7Twelve”) is committed to safeguarding the use of your personal information that we have as your Investment Advisor. 7Twelve (referred to as "we", "our" and "us" throughout this notice) protect the security and confidentiality of the personal information we have and make efforts to ensure that such information is used for proper business purposes in connection with the management or servicing of your account. Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything we can to maintain that trust.
The Information We Collect About You. You typically provide personal information when you complete the paperwork required to become our Client. This information may include your:
• Name and address
• E-mail address
• Phone number
• Account balance
• Social security or taxpayer identification number
• Investment activity
• Accounts at other institutions
In addition, we may collect nonpublic information about you from the following sources: Information we receive on Brokerage Agreements, Managed Account Agreements and other
Subscription and Account Opening Documents; Information we receive in the course of establishing a customer relationship including, but not limited to, applications, forms, and questionnaires; Information about your transactions with us or others.
Information About You That 7Twelve Shares. 7Twelve works to provide products and services that benefit our customers. We may share nonpublic personal information with non-affiliated third parties (such as brokers and custodians) as necessary for us to provide agreed services and products to you consistent with applicable law. We may also disclose nonpublic personal information to other financial institutions with whom we have joint business arrangements for proper business purposes in connection with the management or servicing of your account. In addition, your nonpublic personal information may also be disclosed to you, persons we believe to be your authorized agent or representative, regulators in order to satisfy 7Twelve’s regulatory obligations, and is otherwise required or permitted by law. Lastly, we may disclose your nonpublic personal information to companies we hire to help administrate our business. Companies we hire to provide services of this kind are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to the performance of the specific service we have requested. To repeat, we do not sell your nonpublic personal information to anyone.
Information About Former Investors. 7Twelve does not disclose, and does not intend to disclose, nonpublic personal information to nonaffiliated third parties with respect to persons who are no longer our clients.
Confidentiality and Security. Our employees are advised about the firm's need to respect the confidentiality of our customers' nonpublic personal information. Additionally, we maintain physical, procedural and electronic safeguards in an effort to protect the information from access by unauthorized parties.