Internet Privacy Notice
(as amended November 01, 2019)
We have adopted general policies and procedures concerning confidentiality, proprietary data and privacy of customer personal information, and the information we gather over the Site is protected by those policies and procedures. Generally, we collect non-public personal information about our clients from the following sources:
Information from forms (such as the Account Application and Investment Management Agreement) you fill out and send to us in connection with your investments managed by LGAM or in the Trust (such as your name, address, and social security number);
Information you provide orally to us or our representatives;
Information about the amounts you have managed by LGAM (such as your initial investment and any additions to and withdrawals from your accounts);
Information from electronic sources such as our Web sites or e-mails; and,
Information about any bank account you use for transfers between your bank account and your account(s) with LGAM.
Information about any bank account you use for transfers between your bank account and your capital account in the Trust.
Our policy is that we do not disclose any non-public personal information about our current or former clients to anyone, except as permitted by law. We may voluntarily disclose non-public personal information about our current or former clients to regulatory authorities in connection with our business or that of our affiliates. In addition, we share non-public personal information with certain service providers to the extent permitted by law, and we require those service providers to keep the non-public information confidential. For example, we may provide such information to brokers, attorneys, third-party marketing firms and auditors.
We restrict access to non-public personal information about our clients to employees and service providers who need to know that information to provide services to our clients.
We maintain physical, electronic and procedural safeguards that comply with federal standards to guard clients’ personal information.
II. Collection of Information
In general, you can browse the Site without telling us who you are or revealing any personal information about yourself. We automatically track certain information that your browser makes available whenever you visit a website. This information includes your Internet Protocol address, browser type, browser language and one or more files that may uniquely identify your browser. We may use this information to do internal research on our users’ demographics, interests and behavior to better understand, protect and serve you and our clients. This information may include the URL from which you just came (whether this URL is on the Site or not), to which URL you next go (whether this URL is on the Site or not), your computer browser information and your IP address. We use this information to operate, develop and improve our services.
III. Use and Disclosure of Information
We may use your information to send correspondence and perform services on your behalf in connection with investment-related activities.
We may use personal information about you to analyze Site usage, improve our content and product offerings and customize the Site’s content, layout, and services. These uses improve the Site and better tailor it to meet your needs, so as to provide you with a smooth, efficient and safe experience while using the Site.
We may also share information about you if we believe that disclosure is required under law. For example, we may disclose information in response to a subpoena or to cooperate with regulatory or law enforcement authorities.
IV. Control of Your Personal Information
You can review and change any information you submit to us by contacting us at 1-415-461-8999 or 1-888-568-8884.
Your information is stored on our servers located in the United States. We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy, which may include encryption, “firewalls”, Secure Sockets Layer (SSL) and Transport Layer Security (TLS). We treat data as an asset that must be protected against loss and unauthorized access. We employ security techniques to protect such data from unauthorized access by users inside and outside the firm.
A third party may circumvent our security measures, however, and we do not guarantee that our security measures will successfully prevent third parties from accessing the information we collect. In the event of a security breach involving your personal information, we will make any legally required disclosures to you in the most expedient time possible and without unreasonable delay, consistent with the legitimate interests of law enforcement, or any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information or social security number in an unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
Persons under the age of 18 are not eligible to use the Site and, therefore, we do not knowingly collect any personal information from persons under the age of 18.
VIII. Conditions Of Use
IX. Changes to this policy
If you have any additional questions, please feel free to contact us any time at (415) 461-8999.