Privacy Policy
I. A Message to our Clients
Goshen Rock Capital Management, LLC ( “GRC”) has a company culture devoted to integrity and client service. Integrity and client service are a part of our GRC’s core values and are reflected in the way we serve our clients each day.
This Privacy Policy and Notice (this “Policy”) reflects the practices of GRC and the funds which it manages (“we” or “our”). It describes how “nonpublic personal information,” which includes customer and financial information, may be collected and shared, as well as the steps we take to protect this information from unauthorized access.
These guidelines apply to both current and former clients of GRC and are designed to comply with the privacy provisions in Title V of the Gramm-Leach Bliley Act, as well as applicable federal privacy regulations.
II. Why?
Financial companies choose how they share your nonpublic personal information. Federal law gives consumers the right to limit some, but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your nonpublic personal information. Please read this notice carefully to understand what we do.
III. What?
The types of nonpublic personal information we collect and share depend on the product or service you have with us. This information may be collected from a variety of sources, including:
- Information (such as your name, address, Social Security number, and financial information) we receive from you on subscription agreements, investment management agreements or other account forms;
- Information we receive through your transactions or experiences as our customer, such as your account balance, payment history and securities holdings; and
- Information we may receive from outside companies, such as a credit reporting agency.
IV. Who?
If you are a natural person, this Policy will affect you directly. If you are a corporate investor (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with nonpublic personal information on individuals connected to you for any reason in relation to your investment with us, this Policy will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.
V. Reasons We Can Share Your Nonpublic Personal Information
All financial companies need to share nonpublic personal information to run their everyday business. In the section below, we list the reasons GRC chooses to share your nonpublic personal information.
We collect nonpublic personal information in connection with our everyday business purposes so that we are able to enhance the service we provide to you or to meet regulatory requirements.
Privacy Policy
Moreover, we collect and maintain nonpublic personal information in order to:
- Service your accounts and process your requests efficiently and accurately;
- Identify you and protect your accounts from unauthorized access or identity theft;
- Inform you of financial services and choices that can meet your needs now and in the future.
We may disclose all of the information that we collect, as described above, with nonaffiliated third-parties only when those parties are acting on our behalf, or as required or permitted by law. These third-parties may include:
- Service providers who provide support services to help us administer your financial relationship. They may include auditors, check printers, data processing companies, companies that prepare account statements or otherwise facilitate the processing or servicing of your account and the transactions in your account, or companies that help us market our products to you. These companies are legally obligated to maintain the confidentiality of the information we provide to them, and are restricted from using this information for any reason beyond the performance of specified services on our behalf.
- Other parties as permitted or required by applicable law. These may include, for example, government agencies in response to subpoenas and other legal processes, consumer reporting agencies, or those with whom you have authorized us to share information.
VI. Safeguarding Your Nonpublic Personal Information
- We limit employee access to nonpublic personal information to those who need to know this information in order to serve customer relationships. Employees are educated about the importance of privacy in accordance with our policies and procedures.
- We maintain physical, electronic and procedural safeguards intended to comply with all applicable regulatory standards to guard your nonpublic personal information.
- We strive to maintain complete, current and accurate information about you and your account. If you request a correction to our records, we will respond in a timely manner.
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We reserve the right to change this Policy, and will inform you of any substantive changes. Federal law gives you the right to limit only; (i) sharing for affiliates’ everyday business purposes – information about your credit worthiness, (ii) affiliates from using your information to market to you and (iii) sharing for nonaffiliates to market to you. State laws may give you additional rights to limit sharing. If you would like to exercise these rights to limit sharing or if you have any questions regarding this Policy or your ability to opt out or otherwise limit GRC’s ability to share your nonpublic personal information, please contact GRC’s compliance department at compliance@goshenrock.com.