Client Privacy Policy

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Last updated November 2015.

Model Capital Management LLC (“we”) respects your right to privacy, and is committed to secure the confidentiality and integrity of your personal information. This Policy and Notice describes what information about our current and prospective clients we collect, and how we use it.

Why We Collect Your Information – We gather information about you and your accounts so that we can

  • know who you are and thereby prevent unauthorized access to your information,
  • design and improve the products and services we offer, and
  • comply with the laws and regulations that govern the financial industry.

What Information We Collect – We may collect the following types of nonpublic, personal, and/or confidential information about you:

  • Information about your identity, such as your name and address;
  • Information about transactions in your account(s) managed by us;
  • Information we receive from you on applications, such as your finances or employment.

Sources From Which We Obtain Your Information – We collect nonpublic personal information about Model Capital Management LLC clients such as you from the following sources:

  • Information we receive from you on applications or other forms;
  • Information about transactions in your account(s) managed by us; and
  • Information we receive from our brokerage/custody firm.

What Information We Disclose – Your securities account may be carried by our brokerage/custody firm pursuant to a broker/custody agreement. We may collect, share, and/or disclose information regarding your account with the brokerage/custody firm. Our brokerage/custody firm is contractually obligated to keep the information that we provide them (if any) confidential, and use the information only for the services required and as allowed by applicable law or regulation. We do not disclose any personal information about our clients to anyone, except as required by law and noted above. Moreover, we will not release information about our clients, except as noted above except under the following conditions:

  • We receive your prior written consent, or
  • We believe the recipient to be you or your authorized representative, or
  • We are required by law or regulation to release information to the recipient.

Confidentiality And Security – We maintain physical, electronic and procedural safeguards to guard your personal account information. We also restrict access to your personal and financial data to authorized associates who have a need for these records. We require nonaffiliated organizations that we choose to work with, such as brokerage/custody firms, to conform to our privacy standards and are contractually obligated to keep the information provided confidential and used as requested. Furthermore, we will continue to adhere to the privacy policies and practices described in this notice even after your account is closed or becomes inactive. The examples contained within this Privacy Policy are illustrations and are not intended to be exclusive.

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