Privacy

Maintaining the confidentiality of consumer and customer personal financial information is important to Strategic Global Advisors, LLC (“SGA”). Consumers or customers (collectively, “You” or “Your”) are individuals who seek SGA’s advisory services or have an ongoing relationship with SGA, whereby SGA is providing one or more financial products or services. SGA may collect several types of nonpublic personal information about You, including but not limited to:

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

SGA does not sell personal information to anyone and does not disclose such information to anyone except as permitted or required by law. Information collected may be shared with 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 You by Your 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 Your prior written consent, SGA may disclose the Your name in its marketing materials.

Within SGA, access to information about You is restricted to those employees who need to know the information to service accounts. SGA’s employees are trained to follow our procedures to protect Your privacy and are instructed to access information about You 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 Your nonpublic personal information except as required or permitted by law without giving the You an opportunity to instruct SGA not to disclose such information.