Privacy Policy

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It is the policy of Synchronicity to maintain confidentiality of all customer information. Synchronicity collects specific information from clients, pursuant to the Gramm-Leach-Biley Act of 2001 and FTC Rule 313and NFA Rule 2.30. This information includes name, address, birthdate, net worth, occupation, and investment experience, among other things. Client information may only be shared with firm affiliates, a client’s broker, qualified custodian and/or FCM, certain regulators, and parties for which we are legally compelled to provide such information. Limited customer information may be shared with non-affiliated third party service providers, such as providing monthly statements to our accountant so they may compute performance. All such service providers are required to maintain confidentiality of client information.

 

The only employees having access to client information are those that require such access as part of their job duties. Employees with access to client information are forbidden to disclose such information to unauthorized third parties, and shall hold client information in strict confidence. Breaching this privacy policy is cause for termination. Paper documents shall be kept in a secure (locked) area, and electronic documents containing customer information shall be stored in password protected files or folders. Disposal of paper documents containing customer information shall include shredding of such documents.

 

Synchronicity will provide clients with the firm’s privacy notice upon account opening, and at least annually thereafter.

 

Privacy Notice

 

In the United States of America there are regulations which impose various requirements on a financial institutions’ treatment of client information. These regulations require that financial institutions develop privacy policies and disclose these policies to its clients.

 

Synchronicity considers your privacy one of our utmost concerns. This Privacy Notice outlines our current policies and practices regarding how information about individual clients is collected and used. We will send existing clients an updated Privacy Notice on an annual basis.

 

In order to provide you with individualized service, Synchronicity collects information about you from your account application and other forms that you may deliver to us. Synchronicity also collects information about your transactions with us and our affiliates. We use this information to open an account for you, process your requests and transactions and to provide you with additional information about our products and services. In order to service your account and mail correspondence to you, we provide your personal information to other affiliated independent firms that specialize in providing these services. These firms include our clearing firm(s), trade partners, back office firms, and also our printing/mailing vendors. We require these other independent firms to protect the confidentiality of your information and to use the information only for the limited purpose for which the disclosure is made. We do not disclose any nonpublic personal information about our clients to other independent firms, organizations or individuals except in furtherance of our business relationship with you, or as otherwise permitted or required by law. In addition, if you decide at some point to close your Synchronicity account, we will continue to adhere to the privacy policies and practices described in this notice.

 

We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with US federal standards to guard your personal information.

 

If you prefer that we limit disclosures of personal information about you, you may notify us via email at bupward@synchronicityinvestments.comor by calling (248) 996-7498. If you determine to opt out of this policy, you can instruct us to what extent we are able to disclose your non-public personal information to affiliated third parties. If you have any questions or concerns regarding the privacy of your information at Synchronicity, or would like to discuss your “opt out” options please contact us at your earliest convenience.

2022-Jan