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?

    BakerAvenue 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, confidential client information may be shared with third party investment advisers serving as sub-advisers in order to service the account(s) and act on their 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 our sub-advisers. 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 jl@bakerave.com

  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.