Grace Capital Management Group LLC (referred to as “GCMG”) maintains physical, electronic and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information. Through this policy and its underlying procedures, GCMG attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.
It is the policy of GCMG to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services to the clients. GCMG may disclose the client’s information if GCMG is: (1) previously authorized to disclose the information to individuals and/or entities not affiliated with GCMG, including but not limited to the client’s other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent broker-dealer, investment advisor, account custodian, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. The disclosure of information contained in any document completed by the client for processing and/or transmittal by GCMG in order to facilitate the commencement/continuation/termination of a business relationship between the client and a nonaffiliated third-party service provider (i.e., broker-dealer, investment advisor, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by the client for GCMG (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third-party service provider.
In certain situations, GCMG may share your information with parties that are not affiliated with GCMG, as described below. GCMG recognizes that you have elected to open accounts with GCMG due to the efforts of your investment adviser representative. If he or she elects to leave GCMG for another investment advisory firm, GCMG may allow your investment adviser representative to take your confidential information with him or her to the new firm, subject to the requirements or limitations of applicable law. Your client information may also be shared with a non-GCMG affiliated investment adviser representative and his or her firm if your GCMG investment adviser representative has entered into an agreement to sell all or some portion of their securities, advisory or insurance business to the non-GCMG affiliated investment adviser representative. If you do not want GCMG to share your information (other than as prescribed by law) any non-affiliate, you may contact our chief compliance officer at 239-481-5550. In addition, there are certain states that require you as a client to “Opt-in” before we will share this information with non-affiliated persons. If you live in one of these states, we will ask you to sign an acknowledgement before sharing any information with a non-affiliate.
Should you have any questions regarding the above, please contact our chief compliance officer at 239-481-5550.