US Consumer Privacy Notice

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

Personal information
Sharing personal information
Q&A
Other important information
Contact

Personal information

The types of personal information we collect and potentially share when required, or to provide you services are as follows*:

Name and Address
Date of Birth and Social Security Number
National Registration Number
Passport Number and Driver’s License Number
Familial Relationships
Personal Financial Information
Cash Balances and Account Holdings
Account Activity
Purchase and Sale Transactions
Credit Scores and Credit Worthiness

*Please note that other personal information may be shared for a limited purpose, and only if the client has affirmatively consented.

When you are no longer our customer, we continue to share your information as described in this notice. All financial companies need to share customer’s personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customer’s personal information, the reasons Intermediate Capital Group, Inc. and its affiliated investment advisers (collectively, “ICG”) chooses to share such information, and whether you can limit this sharing.

Sharing personal information

Reasons we can share your personal information	Does ICG share?	Can you limit this sharing?
For our everyday business purposes	Yes	No
For our marketing purposes	Yes	No
For joint marketing with other financial companies	No	N/A
For our affiliates’ everyday business purposes- information about your creditworthiness	Yes	Yes
For our affiliates’ everyday business purposes-information about your transactions and experiences	No	N/A
For our affiliates’ to market to you	Yes	Yes
For non-affiliates to market to you	No	N/A

How does ICG protect my personal information?

Our employees are required to protect the confidentiality of information and comply with our established policies. They may access information only when there is an appropriate reason to do so, such as to administer your accounts. We collect only relevant information about our clients. We restrict your personal information to only those individuals who need to know that information in order to provide services for you. We maintain physical, electronic, and procedural safeguards that comply with state and federal regulations to protect your personal information.

How does ICG collect my personal information?

We collect nonpublic personal information about you from the following sources: (a) Information we receive from you in person or on applications, questionnaires, subscription documents or other forms, such as name, address, social security number, assets and income; (b) Information about your transactions with us, our affiliates, or others; and (c) Information we receive from a consumer reporting agency.

Why can’t I limit all sharing?

ICG limits the collection and use of information to the minimum necessary requirements to deliver our services to you, and to comply with industry rules and regulations. This sharing of information is required in order for us to conduct our everyday business of maintaining your accounts, processing transactions, and administering our business.

Other important information

As described above, we may disclose information we collect from you in connection with our everyday business purposes. Examples of our everyday business purposes include but are not limited to account opening with a broker or custodian, processing transactions, auditing purposes and to protect against fraud or responding to any regulatory authorities, court orders or legal investigations, and managing our client relationships. We reserve the right to change this Privacy Notice. The examples contained within this Privacy Notice are illustrations and are not intended to be exclusive. This Notice complies with federal law and SEC regulations regarding privacy. You may have additional rights under other foreign or domestic laws.

Definitions

Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies. ICG shares with our affiliates.
Non-affiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies. ICG does not share with non-affiliates except as permitted by law.
Joint marketing: A formal agreement between nonaffiliated financial companies that together market financial products or services to you. ICG does not jointly market.

Please note

If you are a new customer, we can begin sharing your information 30 days from the date we sent this Notice. When you are no longer our customer, we continue to share your information as described in this Notice.

However, you can contact us at any time to limit our sharing.