I. What You Should Know
Los Angeles Capital Management LLC (“Los Angeles Capital”) recognizes the importance of keeping information about you confidential and secure and is committed to protecting the nonpublic and personal and financial information of our clients and consumers who obtain or seek to obtain financial products or services. We fulfill this commitment by establishing and implementing policies and systems to protect the security and confidentiality of this information. This Policy applies to Los Angeles Capital.
For California residents only, please refer to the Los Angeles Capital Privacy Notice for California Residents.
This Policy applies to customers to whom Los Angeles Capital provides financial products and/or services. This Policy sets forth our compliance with applicable financial privacy laws, including the Gramm-Leach-Bliley Act. Los Angeles Capital limits access to nonpublic personal and financial information about you to those personnel who need to know the information in order to provide products or services to you. Los Angeles Capital maintains physical, electronic, and procedural safeguards that we believe are reasonably designed to comply with federal standards to protect your nonpublic personal and financial information.
III. Categories of Information We Collect
- Los Angeles Capital collects the following types of nonpublic personal and financial information about you:
- Your name, address, e‐mail address, name of current or former employer, tax identification number, and identifying numbers, and other similar personal and financial information, from you and from identification cards (e.g., passport and driver’s license) and papers you submit to us on applications, subscription agreements or other forms of communications.
- Information about your account balances and financial transactions with us, our affiliated entities or nonaffiliated third parties from our internal sources, from affiliated entities and from nonaffiliated third parties. This includes information about redemptions and additions to your accounts.
- Information about your balances and financial transactions and other personal and financial information, from consumer credit reporting agencies or other nonaffiliated third parties to verify information received from you or others as well as information from third parties such as consultants, referring brokers or advisers, managers, product sponsors and clearing firms, and their service providers.
IV. Categories of Information We Disclose to Non-affiliated Third Parties
Los Angeles Capital occasionally discloses nonpublic personal and financial information about you to non‐affiliated third parties as permitted by law. Some instances when we have shared information include:
- for our everyday business purposes as necessary to execute, process, service and confirm securities transactions that you request or authorize,
- to fulfill our contractual obligations to you or your employer,
- to service and administer your account and commingled investment vehicles in which you are invested,
- to communicate with you as our client, our client contact or employee,
- to market our products and services through joint marketing arrangements,
- to manage our business operations, including but not limited to: managing our products and services; collecting money that is owed to us; and making payments for products and/or services rendered,
- to process any job application submitted by you,
- to manage privacy and security,
- to aid in the detection and prevention of financial crimes,
- to comply with our regulatory requirements, or
- to respond to court orders and other legal proceedings, such as responding to a subpoena.
Los Angeles Capital may disclose nonpublic personal and financial information concerning you to law enforcement agencies, federal or state regulatory agencies, self‐regulatory organizations or other nonaffiliated third parties, if required or requested to do so by a court order, judicial subpoena or to comply with a regulatory obligation.
When your nonpublic personal and financial information is shared with unaffiliated third parties, they are not permitted to use the information for any purpose other than to assist our servicing and administration of your account(s), including helping us improve the services we offer, or as permitted by law.
Nonpublic personal and financial information may be stored by Los Angeles Capital for an indefinite period of time. Access to such information is limited to those personnel who need to know the information in order to provide products or services to you and is password protected.
V. Categories of Information We Disclose to Our Affiliated Entities
Los Angeles Capital regularly discloses your name, address, and account and other identifying numbers, account balances and information about your pending or past transactions to our parent entities, LACM Holdings Inc. and LACM Equity LLC, and our subsidiary, LACM Global, Ltd. for any business purpose.
VI. Information About Our Former Customers
Los Angeles Capital does not disclose nonpublic personal and financial information about former customers to nonaffiliated third parties unless required for regulatory purposes, or requested to do so by a court order, judicial subpoena or regulatory inquiry, or otherwise where we believe in good faith that disclosure is required or permitted by law. Furthermore, Los Angeles Capital does not disclose nonpublic personal and financial information about former customers to nonaffiliated third party systems unless such system was used to service your account.
Los Angles Capital may disclose your name, address, e‐mail address, phone number, taxpayer identification number, and account and other identifying numbers, account balances, information about your past transactions and other personal financial information to our affiliated entities for any business purpose.
VII. Access To Your Information
You are entitled to access personal information that Los Angeles Capital may hold about you. Generally, you will be granted full access to your personal information unless there is a legal or administrative reason to deny access. In such an event, Los Angeles Capital will provide you with the reasons for the refusal. Individuals requesting access to any personal information maintained by Los Angeles Capital should contact the Chief Compliance Officer at firstname.lastname@example.org.
Los Angeles Capital may modify, alter or otherwise update this policy at any time. Los Angeles Capital will promptly post the new policy or summary on its public website including the date it was revised.
IX. More Information
Los Angeles Capital Management LLC
Attn: Compliance Department
11150 Santa Monica Blvd. Suite 200
Los Angeles, California 90025
Revised December 22, 2022