SOPHIS INVESTMENTS LLC
PRIVACY POLICY NOTICE
Sophis Investments LLC takes its responsibility to protect the privacy and confidentiality of its customers’ non-public personal information very seriously. The Adviser shall judiciously keep confidential the affairs of its customers, and shall treat with strict confidentiality client records and financial information. This Privacy Policy Notice explains the manner in which the Adviser collects, utilizes and maintains non-public personal information about its customers as required under Federal law.
Collection of Customer Information
The Adviser collects personal information about customers mainly through the following sources:
*Application forms, customer questionnaires and other information provided by customers in writing, in person, by telephone, electronically or by any other means. This information includes name, address, date of birth, nationality, social security or other tax identification number, government issued identification card information, employment information, assets, income, and other financial and investment qualifications;
*Transactions relating to an account, including account balances, investments and withdrawals; and
*In certain cases, upon your written direction, the Adviser may accept to collect information from consumer reporting agencies, such as your creditworthiness and credit history.
Disclosure of Nonpublic Personal Information
The Adviser does not sell or rent customer information. The Adviser does not disclose nonpublic personal information about its customers to nonaffiliated third parties or to affiliated entities, except as described herein or as otherwise permitted or required by law. For example, the Adviser may share non-public personal information in the following situations:
*To service providers on a “need to know basis” in connection with the administration and servicing of customer accounts, which may include broker-dealers, custodians, transfer agents, accountants, attorneys, and other professionals. The Adviser may also share information in connection with the servicing or processing of account transactions;
*To employees and affiliates of the Adviser on a “need to know basis” in order to provide customers with ongoing advice and assistance with respect to the services provided to them by the Adviser and to introduce them to other Adviser 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 customer to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the customer.
Protection of Customer Information
The Adviser’s policy is to require that all employees, financial professionals and firms providing services on its behalf keep customer information confidential.
The Adviser maintains safeguards to protect customer information, including restricting access to the personal and account information of clients to those Adviser personnel who need to know that information in the course of their job responsibilities. Third parties with whom the Adviser shares customer information must agree to follow appropriate standards of security and confidentiality.
The Adviser’s privacy policy applies to both current and former customers. The Adviser may disclose non-public personal information about a former customer to the same extent as for a current customer.
Changes to Privacy Policy
The Adviser may make changes to its privacy policy in the future. The Adviser will not make any change affecting a customer without first sending such customer a revised privacy policy describing the change. In any case, the Adviser will send each customer a current privacy policy at least once a year as long as he or she continues to be a customer of the Adviser.