This privacy statement explains the manner in which CIC INVESTMENT CONSULTANTS, LLC (collectively “CIC”) collects, utilizes and maintains nonpublic personal information about its Clients, as required under recently enacted Federal legislation. This privacy statement only applies to nonpublic information of Clients who are individuals (not entities).
Collection of Client Information
CIC collects personal information about its Clients mainly through the following sources:
- Investment Management Agreement, Investment Consulting Agreement, and other information provided by the Client in writing, in person, by telephone, electronically or by any other means. This information includes name, address, nationality, tax identification number, and financial and investment qualifications; and
- Transactions, including account balances, investments and withdrawals.
Disclosure of Nonpublic Personal Information
CIC does not sell or rent Client information. CIC does not disclose nonpublic personal information about its Clients to nonaffiliated third parties or to affiliated entities, except as permitted by law. For example, CIC may share nonpublic personal information in the following situations:
- To service providers in connection with the administration and servicing of the Client account, which may include attorneys, accountants, auditors and other professionals. CIC may also share information in connection with the servicing or processing of a Client’s transactions;
- To affiliated companies in order to provide Client with ongoing advice and assistance with respect to the products and services Client has purchased through CIC and to introduce Client to other products and services that may be of value to them;
- To respond to a subpoena or court order, judicial process or regulatory authorities;
- To protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities; and
- Upon consent of a Client to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the Client.
Protection of Client Information
CIC’s statement is to require that all employees, financial professionals and companies providing services on its behalf keep client information confidential.
CIC maintains safeguards that comply with federal standards to protect Client information. CIC restricts access to the personal and account information of Clients to those employees who need to know that information in the course of their job responsibilities. Third parties with whom the Adviser shares Client information must agree to follow appropriate standards of security and confidentiality.
CIC’s privacy statement applies to both current and former Clients. CIC may disclose nonpublic personal information about a former Client to the same extent as for a current Client.
Changes to Privacy Statement
CIC may make changes to its privacy statement in the future.