At Verdis Investment Management we recognize the importance of maintaining the utmost security and confidentiality of our clients’ information. In addition to internal policies and procedures designed to safeguard client information, we prohibit those we do business with from any reuse of that information for purposes other than those intended by Verdis.
This privacy notice applies to all consumers who have a relationship with Verdis Investment Management, which is also referred to herein as “Verdis.” Verdis’ privacy notice is subject to change. For purposes of this notice, client information means personally identifiable information about a consumer who has a relationship with Verdis.
Accordingly, at Verdis we have adopted the following:
Client information security and confidentiality
We take a number of steps to ensure that client information is adequately safeguarded. These steps include the following: 1) implementing a number of physical and electronic security features to prevent unauthorized access; 2) limiting employee access to client information; and 3) conducting periodic reviews of our computer systems, including security features. Additionally, our employees are required to acknowledge their responsibility to maintain the confidentiality of client information.
How we collect client information
We collect client information that: 1) we receive on subscription documents to us for our products and/or services; 2) we receive from processing clients’ accounts with us and the transactions in those accounts, as well as providing services to our clients; 3) we receive about our clients from our affiliated companies; and 4) we receive in response to requests made to third parties about our clients or to confirm information that our clients have provided to us.
How we disclose client information
We may disclose some or all of the client information we collect about our clients under the following circumstances: 1) to verify or complete a transaction; 2) to verify the existence and condition of a client account for a third party, such as another financial institution; 3) to a third party who performs functions on behalf of Verdis (i.e. custodian, fund administrator); 4) to comply with laws, regulations, or a court or government order or request, such as in response to a subpoena or a request by an SEC/FINRA examiner; 5) to inform a client of our other products or services; 6) if a client or any authorized person on the account gives us oral or written permission to do so; or (7) to verify the accuracy of information that a client has provided to us.
We do not share your nonpublic information with other nonaffiliated third parties to market to you. As set forth above, we only share nonpublic information with third parties, as necessary to service your account(s) or as required by law. As such Verdis dues not allow the opting out of the disclosure of such information.
Client information shared among Verdis’ affiliates
Verdis has several affiliates that allow us to provide our clients with an array of financial services that include custody, trust, brokerage, and banking services. We may share some or all of the personal financial information we collect among our affiliates, except as limited herein. By sharing this information among our affiliates, we can serve our clients more efficiently and make it easier for them to do business with us. For example, if a client has an account with us and wants to open an account with one of our affiliated companies, we may share the information he or she provided to us.
Client information about former clients
We apply the same privacy polices and practices to our former clients that we do to our existing clients. Collected client information is retained in accordance with Federal law.
Client information – accuracy
We recognize the importance of maintaining accurate client information that is provided to our clients in various forms, including account statements and billing statements. If a client ever notices that his or her information is inaccurate, we ask they please contact us. Upon notification we will correct any inaccuracies.