1. Protection of Confidential Information
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 and S-AM”). Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some, but not all, sharing. Please take the time to read and understand this Privacy Notice which summarizes the non-public personal information we gather, how we share that information and how we safeguard (protect) that information. (1)
2. What Information Do We Collect?
Baker Avenue Asset Management, LP as a registered investment adviser is obligated to collect certain personally identifiable financial information about our Clients (you) so we may provide suitable financial recommendations (services). Your personal financial information which we gather during the normal course of doing business with you will depend on the services that we provide to you. This information is gathered through:
- Account opening documentation or other forms;
- Custodial applications;
- Governing documents (such as trust or estate records);
- Transactional records (from banks, accountants or other financial services firms); • Internet “cookie” data (an information collection device from an internet (web) server;
- Data or information we gather will include (but is not limited to):
- Social Security numbers;
- Your annual income and net worth;
- Account balances;
- Investment experience;
- Tax liability;
- Risk Tolerances;
- Investment Objectives and Goals; and
- Other personal or family obligations.
In addition, a third party investment adviser, Great Gable Partners, LP is the sub-adviser to one of our investment products; confidential client information may be shared with them to service the account(s) and our contractual obligations.
3. How Does BakerAvenue Protect My Personal Information?
We restrict access to your nonpublic personal information to those employees who need to know that information to provide financial services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.
4. When We Share Your Personal Information and Why You Cannot Limit our Sharing
You cannot limit our sharing of your personal information in cases where we need that information to provide our advisory services to you (this disclosure is necessary in our everyday business).
|REASON||DOES BAKERAVENUE DISCLOSE?||CAN YOU LIMIT THIS?|
|For our everyday business purposes: to process your transactions, maintain your account(s), settle transactions, respond to regulatory inquiries (including court orders and legal investigations or reports to credit bureaus).||YES||NO|
|For our internal marketing purposes: to offer products and services to you.||YES||NO|
|For our affiliate’s everyday business purposes: information about your transactions and experiences or as necessary to provide our services to you.||YES||NO|
|For non-affiliates to market to you.||NO||WE DON'T SHARE|
|For joint marketing with other unaffiliated financial institutions.||NO||WE DON’T SHARE|
5. Information We May Disclose
As stated in the table above, we restrict the disclosure of your personal non-public and confidential information. We only disclose your information as indicated or as required by law. In accordance with Section 248.13 of Regulation S-P (and S-AM), we may disclose all of the information we collect, as described above, to certain non-affiliated 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 non-affiliated 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 may share client information with Great Gable Partners, LP, a sub-adviser to one of our investment products. Great Gable Partners, LP is a SEC registered investment adviser providing investment advice to a private investment limited partnership and sub- advisory services for certain of BakerAvenue’s Clients invested in the small / mid cap core strategy.
Federal law gives you the right to limit our sharing information with an affiliate for their everyday business purposes except when we have a sub-advisory relationship with our affiliate. State laws may give you additional rights to limit sharing. Please contact us in writing to limit the sharing of your personal information at 301 Battery Street, Floor 2, San Francisco, CA 94111 or you may email our Chief Compliance Officer, Jerry Luff at firstname.lastname@example.org
6. Do You Have Questions on Our Privacy Notice?
Please contact BakerAvenue at 415-986-1110.
1 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.