- Information a Client gives us on applications or other written communication and during telephone and in person meetings when the Client establishes an investment advisory relationship or in connection with a partnership investment (which information consists of the Client’s identification and contact information, age, occupation, home address, email address, telephone number, financial information and goals, asset, income and expense profiles, risk tolerance, tax identification numbers, and such additional financial information as we need to provide our services to such Client);
- Information generated by a Client’s other service providers, such as brokerage and custodians, to service client or investor accounts (such as trade tickets, account statements, tax information reports, trade confirmations, confirmations of contributions and withdrawals and similar account information);
- Information potential clients give us on the contact page of our website and the information given to us by potential clients who meet with us to learn more about our firm and our services (this includes basic contact information, basic financial information, such as the person’s age, occupation, family obligations, qualifications as an investor and his or her investable assets, and investment goals); and
- Information we receive from third party solicitors with respect to potential clients or investors accounts (such as names, email addresses, phone numbers and/or mailing addresses).
To provide services to our Clients, Churchill does 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, companies that provide operational services for reconciliation of accounts, and companies that provide shredding services);
- Disclosures to companies as permitted by law, including those necessary to service Client accounts (such as providing account information to brokers and custodians, investor information to private fund administrators, accountants and other fund service providers); and
- Disclosures to third party solicitors who introduce us to Clients (such as the account statements of the introduced Clients).
To fulfill its privacy commitment, except as described above, Churchill restricts access to non-public personal information about our Clients to our employees who need to know such information and maintain physical, electronic, and procedural safeguards that comply with federal standards to guard Clients’ personal information. Currently, Churchill has adopted an information security policy that provides it will conduct employee training regarding safeguarding personal information, conduct risk assessments and use readily available security measures to periodically monitor systems and assets to identify data security events, impose reasonable data access controls, not store consumers’ personal information on its network in clear text, and have a process to secure and inventory devices with access to personal information. If applicable, please contact our office to obtain a copy of our most recent ADV2.
For California Residents: 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 use reasonable efforts to verify that the request is from you 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).