Policy Effective Date: November 1, 2014
What information do we collect?
We collect non-public personal information about clients for business purposes from the following sources:
- Investment Advisory Agreement and New Account Information Form, which may include your name, address social security number, income information, net worth, asset statement, tax circumstances and information about your investment goals and risk tolerance.
- Account History, including information regarding client’s account transactions, which may include the parties to a transaction, the positions held or sold, and pricing.
- Correspondence, including written, telephonic, or electronic between clients and LGA and / or any service providers for client’s accounts.
- We collect information from you when you subscribe to our newsletter or fill out an online form.
What do we use your information for?
In the normal course of business, personal information we collect about clients as described above, may be shared with financial service providers who provide services on behalf of our client’s accounts (such as brokerage firms, custodians, executing brokers, portfolio management software providers, or other client advisors). We may disclose all of the information we collect about clients to non-affiliated third party service providers as necessary to achieve the following:
- Effect, administer or enforce a transaction that a client requests or authorizes.
- In connection with processing or servicing a financial product or service that a client requests.
- In connection with maintaining or servicing a client’s account with the third party. For example, information may be disclosed to others to enable them to perform general administrative activities for us, to assist us in processing a transaction authorized or requested by a client, or to execute transactions on a client’s behalf in conjunction with our Customer Agreement.
- As required by a regulatory authority or law enforcement agency.
- For resolving customer disputes or inquiries
- To persons holding a legal or beneficial interest relating to the customer
- To our attorneys, accountants, or auditors as deemed necessary
- In connection with a proposed or actual sale or merger of our firm
- To comply with a civil, criminal, or regulatory investigation be federal, state, or local authorities
- We employ reasonable precautions to safeguard the security of private customer information, including: physical, technical, and personnel measures
Any of the online information we collect from you may be used in one of the following ways:
- To send periodic emails
- The email address you provide for order processing, may be used to send you information and updates pertaining to your order, in addition to receiving occasional company news, updates, related product or service information, etc.
- Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
How do we protect your information?
We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information.
Do we disclose any information to outside parties?
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Third party links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
California Online Privacy Protection Act Compliance
Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent.
Children’s Online Privacy Protection Act Compliance
We are in compliance with the requirements of COPPA (Childrens Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 13 years old or older.