Analytic Investment Management LLC requires clients provide current and accurate financial and personal information when signing advisory agreements. However, Analytic Investment Management LLC does not collect sensitive information from clients, such as social security numbers, credit card numbers, or account passwords. Analytic Investment Management LLC only stores clients’ information in computers behind a secure firewall. Analytic Investment Management LLC will protect the information clients have provided in a manner that is safe, secure and professional. Analytic Investment Management LLC and its supervised persons are committed to protecting your privacy and to safeguarding that information.
Safeguarding Customer Documents
Analytic Investment Management LLC collects non-public client data in checklists, forms, in written notations, and in documentation provided to us by our clients for evaluation, registration, licensing or related consulting services.
Access to customer records is locked and monitored so that only those with approval may access the files.
No supervised person of Analytic Investment Management LLC who is not so authorized shall obtain or seek to obtain personal and financial customer information. No supervised person of Analytic Investment Management LLC with authorization to access personal and financial customer information shall share that information in any manner without the specific consent of the firm principal. Failure of supervised persons to observe Analytic Investment Management LLC procedures regarding customer and consumer privacy will result in immediate termination.
Sharing Nonpublic Personal and Financial Information
Analytic Investment Management LLC will not share such information with any affiliated or nonaffiliated third party except:
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When necessary to complete a transaction in a customer account, such as with the clearing firm or account custodians;
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When required to maintain or service a customer account;
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To resolve customer disputes or inquiries;
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With persons acting in a fiduciary or representative capacity on behalf of the customer;
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With rating agencies, persons assessing compliance with industry standards, or to the attorneys, accountants and auditors of the firm;
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In connection with a sale or merger of Analytic Investment Management LLC’s business;
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To protect against or prevent actual or potential fraud, identity theft, unauthorized transactions, claims or other liability;
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To comply with federal, state or local laws, rules and other applicable legal requirements;
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In connection with a written agreement to provide investment management or advisory services when the information is released for the sole purpose of providing the products or services covered by the agreement;
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In any circumstances with the customer’s instruction or consent; or
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Pursuant to any other exceptions enumerated in the California Information Privacy Act.
Opt-Out Provisions
It is not a policy of Analytic Investment Management LLC to share nonpublic personal and financial information with affiliated or unaffiliated third parties except under the circumstances noted above. Since sharing under the circumstances noted above is necessary to service customer accounts or is mandated by law, there are no allowances made for clients to opt out.