Introduction
This Privacy Policy is designed to comply with the Gramm-Leach-Bliley Act (“GLBA”), Regulation S-P, and applicable state regulations relating to safeguarding, incident response, and customer notification requirements.
This policy applies to both current and former clients. Client information will continue to be protected after the advisory relationship has ended.
Information We Collect
Non–public personal information may be collected from:
- Information provided in account applications, agreements, and other forms
- Information about transactions with the firm, custodians, or other service providers
- Information received from third parties in connection with servicing client accounts
This may include name, address, email, phone number, Social Security number, account numbers, and other financial information, including account balances, account activity, and transaction records.
How Information Is Used
Client information is used only as necessary to:
- Provide investment advisory services
- Maintain and service client accounts
- Communicate with clients
- Comply with applicable federal and state laws, regulations, and regulatory examinations
- Support internal operations, including identity verification and anti-money laundering compliance
This may include name, address, email, phone number, Social Security number, account numbers, and other financial information, including account balances, account activity, and transaction records.
Disclosure of Information
Client information is not sold to third parties.
Information may be disclosed to non-affiliated third parties only as permitted or required by law. Information may be shared only as necessary in the following circumstances:
- With custodians, broker-dealers, financial institutions, and other service providers, including legal, accounting, and administrative vendors, to maintain and service client accounts
- To effect, administer, or enforce transactions on behalf of clients
- To comply with legal or regulatory requirements, including subpoenas, audits, or examinations
- At the direction of the client or an authorized representative
All third-party service providers are required to maintain the confidentiality of client information and are expected to implement appropriate safeguards consistent with applicable law.
Gaard conducts reasonable due diligence on third-party service providers and maintains oversight designed to ensure that such providers are capable of maintaining appropriate safeguards for client information.
Safeguards and Cybersecurity
Gaard maintains a written information security program designed to safeguard client information. This program includes administrative, technical, and physical safeguards and is reasonably designed to:
- Ensure the security and confidentiality of client information
- Protect against anticipated threats or hazards
- Protect against unauthorized access or use that could result in substantial harm or inconvenience to clients
Administrative, technical, and physical safeguards are maintained to protect client information from unauthorized access, use, or disclosure. These safeguards include secure systems, encryption, access controls, and ongoing monitoring.
An information security and cybersecurity program is maintained to protect client data and respond to potential threats. These safeguards are supported by written policies and procedures that are reviewed and updated periodically.
Access to client information is restricted to personnel with a legitimate business need and limited to those necessary to provide advisory services or support operations.
Incident Response and Data Breach Notification
Gaard maintains a written incident response program designed to detect, respond to, and recover from unauthorized access to or use of client information.
This program includes procedures to:
- Identify and assess incidents involving client information
- Contain and mitigate potential harm
- Restore the security and integrity of systems and data
- Document and evaluate incidents and responses
If a data breach involving client information occurs:
- The incident will be investigated and contained
- Appropriate remediation steps will be taken
- Affected clients will be notified as soon as practicable and without unreasonable delay, in accordance with applicable federal and state laws and regulations, including Regulation S-P where applicable
Notification will be made in a timely manner consistent with regulatory requirements and the nature and scope of the incident.
Administrative, technical, and physical safeguards are maintained to protect client information from unauthorized access, use, or disclosure. These safeguards include secure systems, encryption, access controls, and ongoing monitoring.
An information security and cybersecurity program is maintained to protect client data and respond to potential threats. These safeguards are supported by written policies and procedures that are reviewed and updated periodically.
Access to client information is restricted to personnel with a legitimate business need and limited to those necessary to provide advisory services or support operations.
Electronic Communications
Electronic communications, including email, may not be secure and may be subject to interception or unauthorized access. Reasonable precautions are taken, but risks associated with electronic transmission remain. Clients are encouraged to take appropriate precautions when transmitting sensitive information electronically.
Disposal of Information
Client information is disposed of using methods designed to prevent unauthorized access or reconstruction, including secure deletion or destruction where appropriate.
Recordkeeping
Records relating to the protection of client information, including incidents involving unauthorized access or use of such information and the firm’s response, are maintained in accordance with applicable regulatory requirements.
Privacy Notice Delivery
In accordance with the FAST Act:
- Clients receive this Privacy Policy at the start of the advisory relationship
- Annual delivery is not required provided that this Privacy Policy has not materially changed and client information is not shared with non-affiliated third parties except as permitted by law
- Updated notices will be provided if privacy practices materially change
Client Questions
Questions regarding this Privacy Policy or the handling of client information may be directed to the contact information below.
Gaard Capital LLC
Email: info@gaard.capital
Phone: (805) 265–0221