Privacy

Maintaining the confidentiality of client personal financial information is very important to Strategic Global Advisors, LLC (“SGA”). To provide clients with superior service, SGA may collect several types of nonpublic personal information about clients, including:

• Information from forms that clients may fill out and send to SGA in connection with SGA’s services (such as name, address, and social security number)
• Information a client may give SGA orally
• Information about the amount clients have invested with SGA or in a private investment fund (such as initial investment and any additions to and withdrawals from a capital account)
• Information about any bank account clients may use for transfers between a bank account and SGA’s managed accounts or a capital account of a private investment fund

SGA does not sell or disclose client personal or confidential information to anyone except as permitted or required by law or by the client. Information collected may be shared with the independent auditors in the course of the annual audit of SGA. SGA may also share this information with SGA’s legal counsel and with regulators, as it deems appropriate. SGA may disclose information about a client at the client’s written request (for example, by sending duplicate account statements to someone designated by the client or investor), or as otherwise permitted or required by law. Finally, and upon prior written consent of the client, SGA may disclose the client’s name in its marketing materials.

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. In addition, SGA’s access to information about clients is restricted to those employees and outsource vendors who need the information to support SGA’s client service and/or legal requirements as stated above. SGA’s employees and outsource vendors are trained to follow SGA’s procedures to protect client privacy and are instructed to access information about clients only when they have a business reason to obtain it.

SGA reserves the right to change this privacy policy in the future, but SGA will not disclose client or investor nonpublic personal information except as required or permitted by law without giving the client an opportunity to instruct SGA not to disclose such information. Should you have any questions about our Privacy Policy, please do not hesitate to call Strategic Global Advisors at 949-706-2640.