Privacy Policy
In compliance with Securities and Exchange Commission Regulation S-P (“Regulation S-P”) and other federal laws, Gulf Stream provides notice to its customers to inform them on what types of information Gulf Stream collects about individuals who apply for or obtain its products or services, how it handles and protects such information and the circumstances in which that information will be disclosed to non-affiliated third parties. The provisions of the notice apply to former as well as current customers.I. INFORMATION COLLECTED
Gulf Stream collects nonpublic personal information about its customers for business purposes in connection with its investment management operations. Such information is collected from the following sources:
- Account Opening Documents and Other Forms, which may include information such as a customer’s name, address, social security number, income information, net worth, investment experience, educational background and banking information;
- Account History, such as information regarding the assets in a customer’s account and the account’s transactions, including the parties to a transaction, the positions held or sold, and pricing; and
- Correspondence, written, telephonic or electronic between the customer, Gulf Stream and/or any service providers for the customer’s account.
I. INFORMATION DISCLOSURE TO THIRD PARTIES
Gulf Stream does not disclose any nonpublic personal information about its customers to non-affiliated third parties, except to service providers and as otherwise permitted by law. Nor does it sell any customer’s personal information to any third party.
In the normal course of business, all of the nonpublic personal information collected about a customer, as described above, may be shared with other persons who provide services in connection with such customer’s account (including brokers, administrators, custodians, accountants or attorneys, as well as any other service providers for that customer’s account).
Gulf Stream may also disclose personal information with non-affiliated entities and regulatory authorities as permitted by applicable law. For example, such information may be disclosed to cooperate with regulatory authorities and law enforcement agencies and as necessary to protect Gulf Stream’s rights and property.
If any personal credit reports or personal nonpublic information obtained by Gulf Stream is disposed of, Gulf Stream ensures that it is completely destroyed before disposal.
II. PROTECTING CONFIDENTIALITY AND SECURITY
Gulf Stream maintains physical, electronic, and procedural safeguards to protect its customers’ nonpublic personal information. This information is treated in a confidential manner. Access to nonpublic information about customers is restricted to employees who have an appropriate reason to access it, such as to administer a customer’s account or offer products and services. Gulf Stream educates its employees on the importance of protecting the privacy and security of confidential personal information. In addition, third parties with whom information is shared are required to:
- maintain policies and procedures designed to assure only appropriate access to, and use of information about, Gulf Stream’s customers; and
- maintain physical, electronic and procedural safeguards that comply with federal standards to guard nonpublic information of Gulf Stream’s customers.
If you have any questions or concerns about your Personal Information or this privacy notice, or to receive additional information concerning Gulf Stream’s privacy policies and procedures, please contact Sheila Kirkpatrick at (704) 552-5907, or e-mail skirkpatrick@gulfstreammgmt.com.
Opt-out for Marketing from Our Affiliates: You may limit our affiliates from marketing their products or services to you based on your personal information that we collect and share with them. To opt-out from receiving marketing from our affiliates, please contact Sheila Kirkpatrick at (704) 552-5907, or e-mail skirkpatrick@gulfstreammgmt.com.
