Column Capital Advisors LLC (“Column Capital”, “firm”, “we”, or “our”), as a Registered Investment Adviser, is covered under the definition of a “financial institution” under the Gramm-Leach-Bliley Act and the Securities and Exchange Commission’s (“SEC”) Privacy of Consumer Financial Information Rule (“Regulation S-P”).
This “Privacy Notice” describes how we collect, store, use, disclose and protect your personal information that may directly, or indirectly, identify you during and after your working relationship with us and/or through our “Website.” We use the term “Personal Information” to describe information that can be associated with you and can be used to identify you. Personal Information does not include information that does not identify a specific person or that is publicly available. In particular, this Privacy Notice describes the basis upon which and for what purposes we process your Personal Information, how we share your Personal information and how we protect and safeguard your Personal Information.
The staff of Column Capital realizes that providing Personal Information is an act of trust. Column Capital values its clients’ trust and confidence. We will never sell or share the nonpublic personal information obtained from or in reference to clients. Additionally, we will not sell or share your Personal Information for marketing purposes. All information provided by clients to Column Capital and its staff, and information and advice furnished to clients by us, shall be treated as confidential and shall not be disclosed to affiliated or unaffiliated third parties, except as permitted or directed by clients with written authorization, by application to facilitate the investment services offered by the firm via an unaffiliated financial services provider, or as required by any rule, regulation or law.
Why We Collect and How We Use Personal Information. To conduct regular business, Column Capital may collect Personal Information from sources such as:
• Information reported by the client on applications or other forms the client provides to the firm
• Information about the client’s transactions implemented by the firm or others
• Information developed as part of financial plans, analyses, or investment advisory services
To administer, manage, service, and provide related services for client accounts, it is necessary for Column Capital to provide access to client information within the firm and to nonaffiliated companies, with whom we have entered into agreements.
The disclosure of Personal Information contained in any document completed by the client for processing and/or transmittal by Column Capital to facilitate the commencement/continuation/termination of a business relationship between the client and/or between Column Capital and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, record keeper, insurance company, etc.), including, but not limited to, information contained in any document completed and/or executed by the client in furtherance of the client's engagement of Column Capital (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third-party service provider.
Procedures to Protect Confidentiality and Security of Your Personal Information
Column Capital has procedures in place that limit access to Personal Information to those employees who need to know such information in order to perform business services. In addition, Column Capital maintains physical, electronic and procedural safeguards to guard your Personal Information.
Column Capital has also adopted the following policies in order to safeguard the Personal Information of our clients in accordance with applicable law:
1. Column Capital is committed to protecting the confidentiality and security of the Client Information it collects and will handle Personal Information about clients only in accordance with all applicable laws, rules and regulations. We shall ensure: (a) the security and confidentiality of client records and information; (b) that client records and information are protected from any anticipated threats and hazards; and (c) that unauthorized access to, or use of, client records or information is protected against. These security measures include computer safeguards and secured files and buildings.
2. Column Capital will maintain policies and procedures that are reasonably designed to safeguard Personal Information about clients and only permit appropriate and authorized access to, and use of, Personal Information about clients through the application of appropriate administrative, technical, and physical protections.
3. To the extent required by applicable law, we shall direct each of our service providers to adhere to the Column Capital’s Privacy Policies with respect to all Personal Information about provided to such service providers.
4. Column Capital shall not disclose any Personal Information about its clients or former clients to anyone, except as permitted or required by law.
5. Column Capital shall issue notices of its Privacy Notice to its clients initially and on an annual basis thereafter to the extent required by applicable law.
Linking to Third Party Websites. We may provide links to third party websites. If you follow links to third-party websites not affiliated or controlled by Column Capital, you should review that third-party’s privacy and security policies and other terms and conditions, as they may be different from our Privacy Policies and Notice. We do not guarantee and are not responsible for the privacy or security of these third-party websites, including the accuracy, completeness, or reliability of their information.
Children. Our Website is not directed or intended for individuals under the age of thirteen (13), and we request that these individuals do not provide personal information through the Website. We do not knowingly collect or retain information from children under the age of 13 without parental consent. Visit the Federal Trade Commission website for more information about the Children's Online Privacy Protection Act (COPPA).
Contact Us: Clients are encouraged to discuss any questions regarding privacy policies and procedures directly with Jeffrey J. Yu, Chief Compliance Officer of Column Capital Advisors. Contact information: firstname.lastname@example.org or 317-663-6500.