Privacy Policy Notice
Financial companies choose how they share your personal information. Federal law gives our clients the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this “Privacy Policy Notice” carefully to understand what we do.
Grounded Capital, LLC (the “Adviser”) does not disclose nonpublic personal information about its prospective, existing or former clients to third parties, other than as described below.
Personal information we collect. The Adviser collects personal information about you in connection with providing advisory services. This information includes your social security number and may include other information such as your:
- • Assets;
- • Investment experience;
- • Transaction history;
- • Income; and
- • Wire transfer instructions.
How the Adviser collects this information. The Adviser collects this information through various means. For example, when you give the Adviser your contact information, enter into an investment advisory agreement with the Adviser, buy securities (i.e., interests in a fund) from the Adviser, tell the Adviser where to send money, or make a wire transfer. The Adviser may also collect your personal information from other sources. The Adviser maintains physical, electronic, and procedural safeguards that comply with federal standards to safeguard your nonpublic personal information, which the Adviser believes are adequate to prevent unauthorized disclosure of such information.
How the Adviser uses this information. All financial companies, including the Advisor, need to share customers’ personal information for everyday business purposes. These purposes may include, for example:
- • To provide advisory services to you.
- • To open an account for you.
- • To process a transaction for your account.
- • To market products and services to you.
- • To respond to court orders and legal investigations.
Disclosure to others. The Adviser may provide your personal information to firms that assist the Adviser in servicing your account and have a need for such information, such as a broker. The Adviser may also disclose such information to service providers and financial institutions with whom the Adviser has joint marketing arrangements (i.e., a formal agreement between financial companies that together market financial products or services to you, such as placement agents). The Adviser requires third-party service providers and financial institutions with which the Adviser has joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which the
Adviser discloses the information to them. These sharing practices are consistent with federal privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws. The Adviser notes that the federal privacy laws only give you the right to limit certain types of information sharing that the Adviser does not engage in (e.g., sharing any personal information with others in order for them to market to you).
How the Adviser protects your personal information. To protect your personal information from unauthorized access and use, the Adviser maintains physical, electronic, and procedural safeguards that comply with federal law to safeguard nonpublic personal information, which the Adviser believes are adequate to prevent unauthorized disclosure of such information. These measures include computer safeguards and secured files and buildings.
This Privacy Policy Notice relates to the following entities:
➢ Grounded Capital, LLC
➢ Grounded Botanical Holdings LP
➢ Grounded Botanical Investors LP
Who to contact with questions. If you have any questions about this Privacy Notice, please contact Jennifer Ciresi by email at jciresi@groundedcapital.com.