Privacy Policy
Clinton Investment Management, LLC (referred to as “Clinton” or “CIM”) maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“Personal Information”). This Personal Information may typically include, among other things, the client’s name and address, personal background, tax information, Social Security or taxpayer identification number, date of birth, assets, income, account balances, investment activity, and accounts at other institutions. In addition to the Personal Information we receive directly from clients we may receive Personal Information from third parties that Clients have authorized to provide to us. We may also obtain Personal Information from third-party service providers in order to verify a client’s identity, to prevent fraud, or to help us identify products and services that may be of interest to client. This Privacy Policy applies to current and former Client.
Through this policy and its underlying procedures, Clinton attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.
It is the policy of Clinton to restrict access to all current and former clients’ Personal Information to those employees and entities who need to know that information in order to provide products or services to the client.
Clinton may disclose the client’s Personal Information if Clinton is:
(1) previously authorized to disclose the information to individuals and/or entities not affiliated with Clinton, including, but not limited to the client’s other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, etc.);
(2) required to do so by judicial or regulatory process; or
(3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations.
Clinton does not sell Personal Information.
While Clinton does not collect, use third-party analytics or track information on how our website is used, you should note that the web-server hosting our website may automatically collect a variety of technical and navigational information about the clients and users.
The disclosure of information contained in any document completed by the client for processing and/or transmittal by Clinton in order to facilitate the commencement/continuation/termination of a business relationship between the client and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by the client for Clinton (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider.
Clinton permits only authorized employees and parties who have signed a copy of Clinton’s Privacy Policy to have access to client information. Employees violating Clinton’s Privacy Policy will be subject to Clinton’s disciplinary process. Additionally, whenever Clinton hires other organizations to provide services to Clinton’s clients, Clinton will require them to sign confidentiality agreements and/or the Privacy Policy.
As required by federal law, we will notify you of our privacy policy annually. We reserve the right to modify this policy at any time, and if we make any material changes we will notify you accordingly.
Should you have any questions regarding the above, please contact Claudia Lupinacci, Chief Compliance Officer.