Privacy Policy
Important Information
WHAT DOES DIAMOND TRAIL CAPITAL MANAGEMENT DO WITH YOUR INFORMATION?
Our Commitment to You
Diamond Trail Capital Management (“DTCM”) is committed to safeguarding the use of your personal information that we have as your Investment Adviser. Diamond Trail Capital (referred to as “we”, “our” and “us” throughout this notice) protects the security and confidentiality of the personal information we have and make efforts to ensure that such information is used for proper business purposes in connection with the management or servicing of your account. Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything we can to maintain that trust.
We do not sell your non-public personal information to anyone, nor does DTCM provide such information to others except for discrete and proper business purposes in connection with the servicing and management of your account as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this privacy policy.
The Information We Collect About You
You typically provide personal information when you complete the paperwork required to become our client. This information may include your:
- Name and address
- E-mail address
- Phone number
- Social security or taxpayer
identification number - Assets
- Income
- Account balance
- Investment activity
- Accounts at other institutions
In addition, we may collect non-public information about you from the following sources:
- Information we receive on Brokerage Agreements, Managed Account Agreements and other
- Subscription and Account Opening Documents;
- Information we receive while establishing a customer relationship including, but not limited to, applications, forms, and questionnaires;
- Information about your transactions with us or others
Information about You That DTCM Shares
DTCM works to provide products and services that benefit our customers. We may share non-public personal information with non-affiliated third parties (such as brokers and custodians) as necessary for us to provide agreed services and products to you consistent with applicable law. We may also disclose non-public personal information to other financial institutions with whom we have joint business arrangements for proper business purposes in connection with the management or servicing of your account. In addition, your non-public personal information may also be disclosed to you, persons we believe to be your authorized agent or representative, regulators in order to satisfy DTCM’s regulatory obligations, and is otherwise required or permitted by law.
Lastly, we may disclose your nonpublic personal information to companies we hire to help administrate our business. Companies we hire to provide services of this kind are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to the performance of the specific service we have requested.
To repeat, we do not sell your non-public personal information to anyone.
Information about Former Clients
DTCM does not disclose, and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our clients.
Confidentiality and Security
Our employees are advised about the firm’s need to respect the confidentiality of our customers’ nonpublic personal information. Additionally, we maintain physical, procedural and electronic safeguards in an effort to protect the information from access by unauthorized parties.
We’ll Keep You Informed
We will send you notice of our privacy policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise our privacy policy and will provide you with a revised policy if the changes materially alter the previous privacy policy. We will not, however, revise our privacy policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing.
