Privacy Policy
Investment advisers are required by law to inform their clients of their policies regarding privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law. Federal law gives the customer the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information.
TYPES OF NONPUBLIC PERSONAL INFORMATION (NPI) WE COLLECT
We collect nonpublic personal information about you that is either provided to us by you or obtained by us with your authorization. This can include but is not limited to your Social Security Number, Date of Birth, Banking Information, Financial Account Numbers and/or Balances, Sources of Income, and Credit Card Numbers or Information. When you are no longer our customer, we may continue to share your information only as described in this notice.
Below are the reasons for which CCG may share a client’s personal information:
▪ For everyday business purposes – such as to process client transactions, maintain client account(s), respond to court orders and legal investigations, or report to credit bureaus;
▪ For marketing by CCG – to offer CCG’s products and services to clients;
▪ For affiliates’ everyday business purposes – information about client transactions and experience; or
▪ For non-affiliates to market to clients (only where allowed).
If a client decides to close his or her account(s) or becomes an inactive customer, CCG will adhere to the privacy policies and practices as described in this Policies and Procedures manual, as updated.
CCG restricts access to clients’ personal and account information to those employees who need to know that information to provide products or services to its clients. CCG maintains physical, electronic, and procedural safeguards to guard clients’ NPI.
In addition to CCG’s listed access persons, any IT persons or other technical consultants employed at the firm may also have access to non-public client information at any time. An on-site or off-site server that stores client information, third-party software that generates statements or performance reports, or third-party client portals designed to store client files all hold the potential for a breach of non-public client information.
To mitigate a possible breach of the private information, CCG uses encryption software on all computers and carefully evaluates any third-party providers, employees, and consultants with regard to their security protocols, privacy policies, and/or security and privacy training.
The system is tested and monitored at least annually.
The test conducted by the CCO will include the following activities:
▪ Attempt to access a random sample of firm devices to ensure that proper passwords are in place to prevent access;
▪ Attempt to access users’ accounts with the proper password to ensure that two-factor authentication prevents system access; and
▪ Attempt to restore a sample of files and records to ensure that the restoration process is sufficient and properly configured.
TYPES OF NONPUBLIC PERSONAL INFORMATION (NPI) WE COLLECT
We collect nonpublic personal information about you that is either provided to us by you or obtained by us with your authorization. This can include but is not limited to your Social Security Number, Date of Birth, Banking Information, Financial Account Numbers and/or Balances, Sources of Income, and Credit Card Numbers or Information. When you are no longer our customer, we may continue to share your information only as described in this notice.
Below are the reasons for which CCG may share a client’s personal information:
▪ For everyday business purposes – such as to process client transactions, maintain client account(s), respond to court orders and legal investigations, or report to credit bureaus;
▪ For marketing by CCG – to offer CCG’s products and services to clients;
▪ For affiliates’ everyday business purposes – information about client transactions and experience; or
▪ For non-affiliates to market to clients (only where allowed).
If a client decides to close his or her account(s) or becomes an inactive customer, CCG will adhere to the privacy policies and practices as described in this Policies and Procedures manual, as updated.
CCG restricts access to clients’ personal and account information to those employees who need to know that information to provide products or services to its clients. CCG maintains physical, electronic, and procedural safeguards to guard clients’ NPI.
In addition to CCG’s listed access persons, any IT persons or other technical consultants employed at the firm may also have access to non-public client information at any time. An on-site or off-site server that stores client information, third-party software that generates statements or performance reports, or third-party client portals designed to store client files all hold the potential for a breach of non-public client information.
To mitigate a possible breach of the private information, CCG uses encryption software on all computers and carefully evaluates any third-party providers, employees, and consultants with regard to their security protocols, privacy policies, and/or security and privacy training.
The system is tested and monitored at least annually.
The test conducted by the CCO will include the following activities:
▪ Attempt to access a random sample of firm devices to ensure that proper passwords are in place to prevent access;
▪ Attempt to access users’ accounts with the proper password to ensure that two-factor authentication prevents system access; and
▪ Attempt to restore a sample of files and records to ensure that the restoration process is sufficient and properly configured.
