We consider customer privacy to be an important aspect of our relationship with you. We are committed to maintaining the confidentiality, integrity, and security of our clients’ personal information and have developed policies that are designed to protect this confidentiality while providing high-quality customer service.

 

In the course of providing you with products and services, we will obtain non-public personal information about you. This information may come from sources such as account applications and other forms, from written, electronic or verbal correspondence, from your transactions, from your accountant or other adviser, or from a consumer reporting agency.

 

Hirschmann Capital (“HC”) takes great care to protect personal information about you and when we use it. We may share your information with our service providers to help with servicing your account. These service providers include the custodian, transfer agent, administrator, and accountants. All of these companies act on our behalf and are obligated to keep the information that we provide to them confidential, and to use the information only to provide the services we’ve asked them to perform. We share only the information needed to provide those products and services and to provide a good customer experience.

 

The types of information we collect could include your birthday, address, social security number, passport, driver’s license and financial information such as net worth and investment objectives. We also will receive information about your transactions, account balance, statements and trade confirmations. You have the right to access the data we have about you.

 

We also reserve the right to report personal information to third parties in very limited cases where we believe that disclosure is required by law. This may include, for example, a disclosure in connection with a subpoena, an investigation, an audit or exam.

 

Keeping financial information secure is one of our most important responsibilities. HC considers the protection of personal information to be a foundation of customer trust and a sound business practice. We have implemented procedures that are designed to restrict access to your non-public personal information to those employees who need to know that information to perform their jobs. We maintain physical, electronic and procedural safeguards to guard your non-public personal information. We continually assess new technology for protecting information and we upgrade our systems when appropriate.

 

HC provides experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. We may collect information you provide by interacting with us via social media such as photographs, opinions, or social media account ID. Any content post is also subject to the terms of use and privacy policies of those platforms. Please refer to those privacy policies to better understand your rights and obligations in regard to such content.

 

If you are a former client, these policies also apply to you: we treat your information with the same care as we do information about current clients. For EU residents, HC will maintain your customer record for a period of 5 years after you have ended your client relationship with us as required by the U.S. Securities and Exchange Commission. After that, your personal information will be deleted from HC’s files and network.

 

HC will provide periodic notice of our privacy policy while you maintain a client relationship with us. You can also review our current privacy notice on our website at https://www.hcapital.llc. If you have any questions about our privacy policy or procedures for protecting your personal financial information, please contact our Chief Compliance Officer.