Arin Risk Advisors, LLC (the “Company”, “we”, “our”, or “us”) views protecting private information regarding its clients and potential clients as a top priority. This notice is intended to provide you with an explanation of how we protect your privacy when we collect and use your information, and the steps we take to safeguard your information.
Information we collect:
The Company limits the use, collection, and retention of client or potential client information to what we believe is necessary or useful to conduct our business or to offer quality products, services, and other opportunities that may be of interest to our clients or potential clients.
The Company collects nonpublic personal information about clients and/or potential clients from various sources. These sources and examples of types of information collected include:
- Product and service applications or other forms, such as client surveys, agreements, etc., which typically request name, address, telephone number, social security number or taxpayer ID number, date of birth, employment status, annual income, and net worth;
- Banking and other financial, investment, and tax related information;
- Business holdings, real estate and other entities or enterprises in which you may hold an interest;
- Information about transactions with the Company and account custodian(s), such as account balance, types of transactions, parties to the transactions, and investment history.
- Information received from consumer reporting agencies, such as credit reports.
Disclosure of Information to Nonaffiliated Third Parties – “Do Not Share” Policy
The Company has a “do not share” policy. We do not disclose nonpublic personal information to nonaffiliated third parties, except under one of the GLBA privacy exceptions, as described below. Since the Company currently operates under a “do not share” policy, we are not obligated to provide you with the right to opt out of sharing with nonaffiliated third parties, as long as such entities are exempted as described below. If our information sharing practices change in the future, we will implement opt out policies and procedures, and we will make appropriate disclosures to you.
Types of Permitted Disclosures – The Exceptions
In certain circumstances, the Company may share your nonpublic personal information with certain nonaffiliated third parties. These circumstances include sharing information with a nonaffiliate (1) as necessary to effect, administer, or enforce a transaction that you request or authorize; (2) in connection with processing or servicing a financial product or a service you authorize; and (3) in connection with maintaining or servicing your account with us.
- Service Providers
From time to time, the Company may have relationships with nonaffiliated third parties (such as attorneys, auditors, accountants, brokers, custodians, and other consultants), who, in the ordinary course of providing their services to us, may require access to information containing nonpublic information. These third-party service providers are necessary for us to provide our investment advisory services. When we are not comfortable that service providers (e.g., attorneys, auditors, and other financial institutions) are already bound by duties of confidentiality, we require assurances from those service providers that they will maintain the confidentiality of nonpublic information they obtain from or through us. In addition, we select and retain service providers that we believe are capable of maintaining appropriate safeguards for nonpublic information, and we will require contractual agreements from our service providers that they will implement and maintain such safeguards.
- Processing and Servicing Transactions
The Company may also share information when it is necessary to effect, administer, or enforce a transaction requested or authorized by you. In this context, “necessary to effect, administer, or enforce a transaction”: includes what is required or is a usual, appropriate, or acceptable method:
- To carry out the transaction or the product or service business of which the transaction is a part, and record, service, or maintain your account in the ordinary course of providing the financial service or financial product;
- To administer or service benefits or claims relating to the transaction or the product or service of which it is a part;
- To provide a confirmation, statement, or other record of the transaction, or information on the status or value of the financial service or financial product to you or your agent or broker.
- Sharing as Permitted or Required by Law
The Company may disclose information to nonaffiliated third parties as required or allowed by law. For example, this may include disclosures in connection with a subpoena or similar legal process, a fraud investigation, recording of deeds of trust and mortgages in public records, an audit or examination, or the sale of an account to another financial institution.
By understanding how the Company shares data with you, your agents, service providers, parties related to transactions in the ordinary course of business, or joint marketers, the Company endeavors to ensure that your data is shared only within the exceptions noted above.
Regulation S-P requires that the Company amend its Privacy Policy and promptly distribute a revised disclosure to clients, if there is a change in the Company’s collection, sharing, or security practices.
Joint Relationships
If two or more individuals jointly obtain a financial product or service from the Company, the Company may satisfy the initial, annual, and revised notice requirements by providing one notice to those individuals jointly.
Safeguarding of Client Records and Information
The Company has implemented internal controls and procedures designed to maintain accurate records concerning your personal information. You have the right to contact the Company if you believe that Company records contain inaccurate, incomplete, or stale information about you. The Company will respond in a timely manner to requests to correct information.
To protect your information, including consumer report information, the Company maintains the following security measures and safeguards for the storage of, access to, and disposal of your personal information, including consumer report information, obtained and/or maintained in hard copy and/or electronically, as well as access and protections of its computer and information systems:
- limiting access to nonpublic and consumer report information to those Associated Persons who require the information in order to help us provide services;
- locking rooms and file cabinets where paper records are stored;
- protecting storage areas against destruction or potential damage from environmental hazards;
- storing electronic nonpublic and consumer report information on a secure server that is accessible only with a password;
- maintaining secure backup media;
- storing archived data off-line and/or in a physically-secure area;
- supervising the disposal of records containing nonpublic and consumer report information;
- shredding nonpublic and consumer report information recorded on paper and storing such material in a secure area until it is collected by a recycling service;
- erasing all data when disposing of computers, diskettes, magnetic tapes, hard drives, or any other electronic media containing nonpublic and consumer report information;
- disposing of outdated nonpublic and consumer report information promptly;
- using anti-virus software that updates automatically; and maintaining up-to-date firewalls
If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.
ARA reserves the right to change these Privacy Principles, and any of the policies or procedures described above, at any time without prior notice. However, you will be promptly provided with a current copy of our privacy notice upon material changes or upon request. So long as you remain an active customer, you will receive a current copy of our privacy notice at least annually. These Privacy Principles are for general guidance and do not constitute a contract or create legal rights, and do not modify or amend any agreements we have with you.
If you have questions about this privacy policy, or if you wish to amend or rescind your written instructions below at any time, please contact us at (610) 822-3400, via email at [email protected] or by writing us at 1100 East Hector Street, Suite 215, Conshohocken, PA 19428-2388.
