Privacy Policy
The information contained in this section is also detailed in the Privacy Requirements section of Accession Partners LLC’s Compliance Policies and Procedures Manual. This statement is provided to all clients in accordance with the rules and regulations of the Gramm-Leach-Bliley Act of 1999.
As a registered investment advisor, Accession Partners LLC and its investment adviser representatives will gather and develop personal information regarding our clients. This information will be gathered and developed by us for the following purposes:
To determine the client’s financial goals and objectives
To determine the level of advisory services needed and desired by the client
To provide the client with specific recommendations regarding advisory services
To provide the client with specific recommendations regarding financial products
To provide ongoing support and recommendations regarding financial products held in the client’s account
Client information that Accession Partners LLC will collect may include, but not be limited to the following:
Information received from clients on financial inventories through consultations with its representatives. This information may include personal and household information such as income, spending habits, investment objectives, financial goals, statements of account, and other records concerning the clients’ financial conditions and assets, together with information concerning employee benefits and retirement plan interests, wills, trusts, mortgages, and tax returns.
Information developed as part of analyses or investment advisory services.
Information concerning investment advisory account transactions.
Information about clients’ financial products.
All information provided by clients to Accession Partners LLC (including our investment advisor representatives and administrative personnel), and information and advice furnished by Accession Partners LLC to you, is treated as confidential and not disclosed to affiliated or unaffiliated third parties, except as (1) permitted by you with written authorization, (2) shared in a manner necessary to facilitate the advisory services provided by Accession Partners LLC or (3) as required by any rule, regulation or law of any regulatory or self–regulatory organization to which Accession Partners LLC or our investment advisor representatives may be subject. For example, you may ask Accession Partners LLC to provide information to your other service providers, such as your accountant, and we are pleased to be of assistance when you direct us to share information. Regulatory and self-regulatory bodies generally conduct routine audits of investment advisers to review books and records, and in the process may review client information. Additionally, your account custodians and their personnel will have access to and review client data for internal purposes.
When a client account is closed, Accession Partners LLC will continue to keep all client information confidential in accordance with the principles stated in its privacy policy.
A copy of the Privacy Policy Notice will be delivered to all clients in writing by at least one of the following methods:
By hand-delivering a copy to the client
Mailing a copy to the client’s address on record
If business is conducted electronically, a copy may be sent by electronic mail or a notice may be posted on an electronic site as long as the client acknowledges receipt of the Privacy Policy Notice prior to the client obtaining any services or products from Accession Partners LLC
A copy of the Privacy Policy Notice will be provided to the client no later than the time a client establishes a relationship with Accession Partners LLC unless this situation would cause a delay in the client obtaining services and the client agrees to accept the notice at a later date. When this situation applies, a copy of the Privacy Policy Statement will be delivered to the client within a reasonable time period following the transaction.
Any time a change is made to the Privacy Policy, the statement to clients will be revised. The revised statement will be given to all affected clients prior to any disclosure of information. In addition, Accession Partners LLC will provide a copy of its Privacy Policy Statement to all current and existing clients at least annually.