Deerfield Financial Advisors, Inc. (“Deerfield”) is committed to safeguarding the use of clients’ personal information that is made available to us as their investment adviser. Deerfield (“we”, “our” and “us”) protects the security and confidentiality of the personal information we have and makes efforts to ensure that such information is used for proper business purposes in connection with the management or servicing of client accounts.
Our relationship with clients is our most important asset. We understand that clients have entrusted us with their confidential information, and we do everything we can to maintain that trust. Deerfield does not sell clients’ non-public personal information to anyone, nor do we provide such information to others except for discreet and proper business purposes in connection with the servicing and management of clients’ accounts as discussed below. Our approach to privacy and the collection and use of clients’ personal non-public information are set forth in this privacy policy.
PRIVACY POLICY BACKGROUND
Deerfield Financial Advisors, Inc. is a U.S. Securities and Exchange Commission (“SEC”) registered investment advisor and has developed this policy as required by SEC Regulation S-P and the U.S. Gramm-Leach-Bliley Act of 1999. Regulation S-P and the U.S. Gramm-LeachBliley Act of 1999 require Deerfield to implement policies and procedures to protect the non-public personal information of clients that Deerfield collects in the normal course of conducting its business, and that Deerfield shall provide a notice to such persons that describes our privacy policy.
THE INFORMATION WE COLLECT ABOUT YOU
Clients typically provide personal information when they complete a new account application. Information is also collected from the planning process that guides clients’ strategy. This information may include the following:
- Name and address
- Email address
- Phone number
- Social Security or taxpayer identification number
- Assets
- Income
- Personal objectives or priorities
- Account balance
- Investment activity
- Location of assets and accounts
In addition, we may collect non-public information about clients from the following sources:
- Information we receive on subscription agreements, managed account agreements and other subscription and account opening documents;
- Information we receive in the course of establishing a client relationship including, but not limited to, applications, forms, questionnaires, and data through our web site; and
- Information about client transactions with us or others.
LIMITING COLLECTION OF INFORMATION
Deerfield only collects personal information necessary for business purposes, which includes information for client account administration, planning, and strategy development, and information that is required for regulatory purposes.
INFORMATION ABOUT YOU THAT DEERFIELD SHARES
Deerfield restricts access as much as possible to clients’ personal and account information to employees and agents in order to provide services for which clients have hired Deerfield. We may also disclose non-public personal information to non-affiliated third parties (such as brokers and custodians) as necessary for us to provide agreed services and products to clients consistent with applicable law. We may also disclose non-public personal information to other financial institutions with whom we have joint business arrangements for proper business purposes in connection with the management or servicing of clients’ accounts. In addition, clients’ non-public personal information may also be disclosed to people we believe to be their authorized agent(s), representative(s), or regulators in order to satisfy Deerfield’s regulatory obligation, and as otherwise required or permitted by law. Lastly, we may disclose clients’ non-public personal information to companies we hire to help administer our business. Companies we hire to provide services of this kind are not allowed to use clients’ personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of clients’ personal information to the performance of the specific service we have requested. Clients have the right to opt out of the sharing of their non-public personal information to non-affiliated parties and may do so via their designated support channels or by contacting Deerfield’s Chief Compliance Officer at 317-469-2455. Please note that this may affect our ability to provide agreed services. To repeat, we do not sell clients’ non-public personal information to anyone. We will not share clients’ personal information with a financial company for joint marketing purposes except as required or permitted by law.
INFORMATION ABOUT FORMER INVESTORS
Deerfield does not disclose, and does not intend to disclose non-public personal information to nonaffiliated third parties with respect to people who are no longer our clients.
CONFIDENTIALITY AND SECURITY
Our employees are regularly advised about the firm’s need to protect and respect the confidentiality of our clients’ non-public personal information. Additionally, we maintain physical, procedural, legal, and electronic safeguards in an effort to protect the information from access by unauthorized parties.
WE WILL KEEP YOU INFORMED
We will send you notice of our privacy policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise our privacy policy, and we will provide you with a revised policy if the changes materially alter the previous privacy policy. We will not, however, revise our privacy policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify clients and provide clients with an opportunity to opt out of information sharing. At all times, you may request our current privacy policy by contacting Deerfield at 317-469-2455 or by email at mkalasmiki@deerfieldfa.com.
Deerfield Financial Advisors, Inc. (“Deerfield”) is an SEC registered investment adviser located in the State of Indiana. Deerfield and its representatives are in compliance with the current notice filing requirements imposed upon SEC registered investment advisers by those states in which Deerfield maintains clients. Deerfield may only transact business in those states in which it is notice filed or qualifies for an exemption or exclusion from notice filing requirements.
Deerfield’s web site is limited to the dissemination of general information regarding its investment advisory services to United States residents residing in states where providing such information is not prohibited by applicable law. Accordingly, the publication of Deerfield’s web site on the Internet should not be construed by any consumer and/or prospective client as Deerfield’s solicitation to effect or attempt to effect transactions in securities or the rendering of personalized investment advice for compensation over the Internet.
Furthermore, the information resulting from the use of tools or other information on this Internet site should not be construed, in any manner whatsoever, as the receipt of, or a substitute for, personalized individual advice from Deerfield. Any subsequent, direct communication by Deerfield with a prospective client shall be conducted by a representative that is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides. For information pertaining to the registration status at Deerfield, please contact the United States Securities and Exchange Commission on their web site at www.adviserinfo.sec.gov.
A copy of Deerfield’s current written disclosure statement discussing Deerfield’s business operations, services, and fees is available from Deerfield upon written request. Deerfield does not make any representations as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to Deerfield’s web site or incorporated herein and takes no responsibility therefore. All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.
