Statement of policy regarding client privacy
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Our commitment to your privacy
Protecting our clients’ privacy is of paramount importance to Fairview
Capital Investment Management, LLC (“Fairview Capital” or “Advisor”).
It is Fairview Capital’s policy that no private client financial
information obtained by us is sold or made available to third parties
except that:
• Third parties may be used by Advisor to assist in the management
or maintenance of client accounts (such as a client’s custodian);
• Client information may be released in accordance with applicable
laws and regulations. We will not share nonpublic personal information about our clients
with nonaffiliated third parties without prior client consent, except
for specific purposes described below. This notice explains our collection,
use and safeguarding of client information.
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How Fairview Capital gathers 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 writing, in person, by telephone, electronically or
by any other means. This information may include a client’s name,
address, phone number, email 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. This information may include
the client’s account balances, positions, investment interests and
history;
• Consumer reporting agencies. This information may include account
information and credit history; and Public sources.
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Sharing information with nonaffiliated third parties
We only disclose non-public client information to nonaffiliated
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 or an operating unit; 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. For example, we do not sell client lists and we will not
sell client names to catalogue companies.
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Opt out provision
If, at any time in the future, it is necessary to disclose any of
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.
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Former clients
Our Privacy Policy continues to apply to all former clients.
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To whom this policy applies
This Privacy Policy applies to individuals who obtain or have obtained
services from Fairview Capital used primarily for personal, family
or household purposes.
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Security practices and information accuracy
We take steps to safeguard client information. We restrict access
to the personal and account information of our clients to our employees
and agents 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 we can. If you believe that any information
about you is not accurate, please let us know.
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Other information
We reserve the right to change this Statement of Privacy Policy. The
examples contained within this Privacy Policy are illustrations and
they are not intended to be exclusive. If you have any questions about
our Privacy Policy, please contact Marcia Nakamura, Chief Compliance
Officer at 415 464 4640. |