Throughout the policy, we refer to non-public information that personally identifies you or your accounts as “personal information.”
Collection of Personal Information
We collect personal information about you to help us serve your financial needs, process your requests and transactions, provide client service and fulfill legal and regulatory requirements. The personal information we collect about you includes:
- Information you provide to us on applications and other forms (which may include a client’s name, address, social security number and occupation, as well as information about the client’s investment goals and risk tolerance)
- Account history, including information about the transactions and balances in a client’s account
- Correspondence – written, telephonic or electronic – between a client and APC
Protecting Personal Information
We do not disclose any personal information about you to anyone except as permitted by law. We limit access to your personal information to those employees who need to know in order to conduct our business, and to manage and service your account. Our employees are required to maintain and protect confidentiality of your personal information and must follow established procedures to do so. We maintain physical, electronic and procedural safeguards to guard your personal information.
Disclosure of Personal Information
We may share the personal information described above for business purposes to affiliates (e.g., ACR Alpine Capital Research, LLC) and certain third parties who are not affiliated with us
(e.g., administrators, auditors, brokers, and custodians), under one or more of the following circumstances:
- In order to facilitate the management of your account
- If you request or authorize the disclosure of the information
- To regulatory authorities as permitted by applicable law
Non-affiliated third parties with whom we share personal information are contractually obligated to maintain strict confidentiality and maintain our privacy standards when handling a client’s personal information. Affiliated entities are defined as companies related by common ownership or control.