Geneva Capital Management Ltd. (“Geneva”) is committed to protecting the confidentiality and security of information we collect about clients. This commitment applies to both current and former clients. In this notice, we refer to non-public information that identifies you or your accounts as “personal information.” The purpose of this notice is to describe Geneva's policy concerning the confidentiality and security of your personal information.
Our relationship with our clients is the most important asset of our firm. We strive to maintain your trust and confidence, an essential aspect of which is our commitment to protect your personal information to the best of our ability. We believe that all of our clients value their privacy, so we will not disclose your personal information to anyone outside our firm unless disclosure is:
1. required or permitted by law (for example, to cooperate with regulators or law enforcement authorities);
2. at the direction of you or your authorized representative; or
3. reasonably necessary to provide you with our services or furnish you with the information necessary to value our services.
Geneva collects and maintains personal information about you and your account in order to provide you with our services. Information we collect includes personal information about you from various sources, including:
Account Information
We receive information from you to open an account or provide investment advice (such as your name, social security number, address, telephone number and financial information such as assets, income, account balance(s), investment activity and other investments);
Transaction Information
We generate personal information about you in the course of servicing your account (such as trade tickets and account statements, account balances, positions and history); and
Third Party Information
We may receive personal information about you or your account from third parties (such as trade confirmations and custodian statements from your bank or brokerage firm).
In order for us to provide investment management services to you, we disclose your personal information in very limited circumstances, which include:
1. Disclosures, subject to strict confidentiality agreements, to companies which perform services on our behalf (such as technology consultants who assist us in maintaining our computer systems, or auditors who assist us in verifying our performance numbers and valuing our services);
2. Disclosures to companies which help us process or service your transactions or account(s) (such as providing account information to brokers and custodians); and
3. Disclosures at your request to attorneys, accountants, and other individuals or firms to assist them in providing services to you.
To fulfill our privacy commitment, we have instituted policies and procedures reasonably designed to safeguard the personal information we maintain about our clients. These include:
1. Adopting policies and procedures that put in place physical, electronic, and other safeguards to keep your personal information safe while in our possession and upon destruction;
2. Limiting employee access to your personal information for business purposes only. All employees are trained and required to safeguard such information;
3. Requiring third parties who perform services for us to agree by contract to keep your personal information strictly confidential; and
4. Protecting information concerning our former clients to the same extent as that concerning our current clients.
For additional information about our privacy policy, please contact Geneva Capital Management at: (414) 224-6002 or (800) 501-3703.
