Spring Delta Asset Management (“Spring Delta”) is committed to maintaining the confidentiality, privacy and security of our clients’ non-public personal information. This commitment extends to all clients with whom Spring Delta Asset Management has a relationship, including current, former and prospective clients.
Spring Delta Asset Management comes into possession of and/or collects non-public personal information about our clients (the “Information”):
· from applications, correspondence, account contracts, fiduciary documents and other documents and forms;
· from client transactions with us, account activity and holdings; and,
· from third parties from which clients have authorized us to obtain Information.
Spring Delta entities may collect and retain certain information about you in order to provide a variety of financial services, including investment management and financial advice; to facilitate investment in a variety of investment products; and to engage in marketing and advertising in relation to such products and services. This can include website and systems administration, storage and review of various types of communications, and other types of data processing.
Spring Delta does not disclose Information about our clients or former clients to third parties except as permitted by law. Third party processors or service providers may have access to Information of clients in order to provide or assist Spring Delta in providing services to Spring Delta clients. In all cases, such third parties are prohibited from using, disclosing or releasing Information outside the scope of providing such services and have executed contracts containing confidentiality provisions.
In the event that Spring Delta intends to disclose Information to a third party that is not providing services to Spring Delta, Spring Delta will notify all affected clients of such intended disclosure. Each such client will be advised of the nature of the disclosure and given instructions on how to opt out. At present, Spring Delta has no intention of disclosing Information to third parties beyond the necessary disclosures to processors and service providers and as otherwise permitted by law.
Spring Delta restricts access to Information about clients to those employees who need to know that Information to provide services to such clients. Spring Delta maintains physical, electronic and procedural safeguards that comply with state and federal regulations to guard client Information. The Company’s independent auditor examines the control objectives established by the Company related to Investment Management, Trust and Custody services and performs testing to determine whether those controls tested were operating with sufficient effectiveness to provide reasonable assurance that the control objectives were achieved
By sharing our privacy practices, we trust that our clients and investors will better understand how we keep their personal information confidential and secure while using it to provide services and products. Generally speaking, Spring Delta clients and investors who receive information from or transact business with Spring Delta though our websites are covered by the terms and conditions of use and any privacy policies or notices posted on the websites they visit. Because of the nature of our business and the variety of products we offer and investors we serve, different privacy policies or principles may apply depending on your location or the nature of your relationship with Spring Delta For more information about our privacy practices, we encourage you to visit our websites and review the privacy information available there.
Revised June 2020
Spring Delta Asset Management, LLC
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