I. What You Should Know
Los Angeles Capital Management and Equity Research, Inc. (“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
In our offices, 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 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 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 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 and financial information about you to affiliates and non-affiliates 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 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 process any job application submitted by you,
- to manage privacy and security, 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 Entity
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 subsidiary, LACM Global, Ltd. for any purpose.
VI. Online Tracking Policy
VII. 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 ID, and account and other identifying numbers, account balances, information about your past transactions and other personal financial information to our affiliated entities for any 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 with the date it was revised.
X. More Information
Los Angeles Capital Management
Attn: Compliance Department
11150 Santa Monica Blvd. Suite 200
Los Angeles, California 90025
Effective October 11, 2019
Reminder About Los Angeles Capital's Financial Products
Financial products offered by Los Angeles Capital and its subsidiary, LACM Global, Ltd. ("LACM Global"), are not guaranteed by any bank, not insured by the Federal Deposit Insurance Corporation and are not obligations of Los Angeles Capital or LACM Global. Such products are subject to investment risks including possible loss of the principal amount committed or invested and earnings thereon.