Our Privacy Policy

Protecting our clients’ privacy is of paramount importance to our Firm. It is our policy that no private client financial information obtained by us is sold or made available to any third parties except that:

• Third parties may be used by the Advisory Firm to assist in the management or maintenance of client accounts (such as a client’s custodian); and
  
• Client information may be released in accordance with applicable laws and regulations.
  

We will not share nonpublic personal information about our clients with non-affiliated third parties without prior client consent, except for specific purposes as described below. This notice explains our collection, use and safeguarding of our clients’ information.

In connection with providing clients with investment management services, we may obtain information about them from the following sources:

• Client agreements and other information that clients provide to us, whether in written, in person, by telephone, electronically or by any other means. This information may include a client’s name, address, phone number, e-mail address, social security number, employment information, income, investment experience, and credit references;
  
• Personal tax returns provided by the client;
  
• Transactions on a client’s behalf which may include the client’s account balances, positions, investment interests, and history; and
  
• Public sources.

We only disclose non-public client information to non-affiliated third parties without prior client consent when we believe it necessary for the conduct of our business or as required or permitted by law, such as:

• If you request or authorize the disclosure of the information;
  
• To provide client account services or account maintenance;
  
• To respond to a subpoena or court order, judicial process, law enforcement or regulatory authorities;
  
• To perform services for the firm or on its behalf to develop or maintain proprietary trading or other software;
  
• In connection with a proposed or actual sale, merger or transfer of all or a portion of our business; and
  
• To help us prevent fraud.
  

We do not make any disclosure of client nonpublic personal information to other companies who may want to sell their products or services to you.

If, at any time in the future, it is necessary to disclose any client personal information in a way that is inconsistent with this policy, we will give our clients advance notice of the proposed disclosure so that they will have the opportunity to opt out of such disclosure.

We take steps to safeguard client information. We restrict access to the personal and account information of our clients to our employees and advisors for business purposes only. We maintain physical, electronic and procedural safeguards to guard your personal information. Additionally, we have internal controls to keep client information as accurate and complete as possible. If you believe that any information about you is not accurate, please let us know.

If you have any questions about our Privacy Policy, please contact Barbara Leonard, Chief Compliance Officer at 904-646-0310 or bleonard@dellaportafinancialadvisors.com