- Information received to open an account or provide investment advice or in connection with a partnership investment (such as home address, telephone number, and financial information);
- Information that is generated to service client or investor accounts (such as trade tickets and account statements); and
- Information that is received from third parties with respect to client or investor accounts (such as trade conformation from brokerage firms, or tax information).
In order to provide services to our Clients and partnership investors, Churchill and its affiliates do disclose personal information in very limited instances, which include:
- Disclosures to companies – subject to strict confidentiality agreements – that perform services on our behalf (such as technology consultants who assist us in maintaining our computer systems);
- Disclosures to companies as permitted by law, including those necessary to service client and partnership investor accounts (such as providing account information to brokers and custodians); and
- Disclosures to Third Party Solicitors who introduce us to Clients (such as account statements).
To fulfill its privacy commitment, Churchill and its affiliates restrict access to non-public personal information about our Clients and partnership investors to our employees and maintain physical, electronic, and procedural safeguards that comply with federal standards to guard Clients’ personal information. For a copy of our most recent ADV2, please contact our office.
We sometimes receive contact information of potential clients from other firms, such as Third Party Solicitors, who believe that those potential clients would benefit from our services. The categories of information we receive in those cases include names, email addresses, phone numbers and/or mailing addresses, and we only use that information to contact those persons. We do not and will not sell or share this information with anyone outside of our firm.
The information we gather from potential clients who meet with us consists of basic financial information, such as the person’s age, occupation, family obligations, qualifications as an investor and his or her investable and non-investable assets, and we may at that time confirm and/or collect additional contact information and information regarding goals and risk tolerance. We do not and will not sell or share this information with anyone outside of our firm.
If we have your information as a result of your visit to our website, a third party providing your information to us or your meeting with us, you have the following rights (1) to request a description of the categories information we have collected about you in the last 12 months, (2) to request the specific pieces of personal information we have about you, and (3) to request a copy of the information we have about you twice in a 12-month period. We will provide that information to you within 45 days of such a request. Before we send you such information, however, we will verify that the request is from you, typically by matching at least 2 or 3 data points of information you previously provided, depending on the request. You also have the right to request that we delete your personal information from our records, except to the extent we are required by law to retain any record. We will request you to verify such a request to delete your data in the same manner.
Please contact us if you would like more information about any of the above data collection practices, or how to request us to send you your data or to delete your data, or if you are disabled and you need a copy of this notice prepared for you in a manner that is accessible. Any such request may be made via our toll-free phone number (877-937-7110), or by submitting the request through the “Contact Us” link at https://www.churchillmanagement.com/contact/.