INFORMATION WE COLLECT
In the normal course of providing clients with investment advisory advice, RAM may receive or be in receipt of certain non-public, personally identifiable financial and/or private information from its clients, their financial representatives and/or other third party delegates. RAM may also gather information about clients during the normal course of its business from various forms or other applications, or from transactions clients conduct with RAM and/or its affiliates, or that RAM may place on clients’ behalf. RAM collects and uses this information for the sole purpose of offering the highest quality investment advisory services to clients.
INFORMATION WE DISCLOSE
All non-public information that we directly or indirectly receive regarding our clients or former clients is held in the strictest confidence in accordance with our professional and legal obligations, and is not released to people outside RAM except with the client’s written consent, as otherwise set forth herein or as required by law. We may disclose some or all of the information we collect, as described above, to certain nonaffiliated third parties such as attorneys, accountants, auditors and persons or entities who assist us in our business or who are assessing our compliance with industry standards and SEC and/or State Regulations. We may also disclose information to regulators or other governmental entities as permitted or required by law.
A client’s nonpublic personal information is used only for our business purposes, and we do not sell client information to anyone under any circumstances. At a client’s direction, we may share certain information with related or affiliated entities or third parties who assist us with providing our services including outsourced service providers located outside of the United States.
CONFIDENTIALITY AND SECURITY
Within RAM, access to a client’s non-public information is restricted to those individuals who require that information in the ordinary course of servicing a client’s account. Where a client’s non-public information is shared or reviewed by any nonaffiliated third party, RAM will review that nonaffiliated third party’s privacy policies on a best efforts basis to insure such policies prohibit such third parties from disclosing or using the information other than to carry out the purposes for which we may disclose the information.
In order to guard a client’s non-public personal information from unauthorized disclosure, we maintain the physical, electronic, and procedural safeguards that comply with our professional standards as well as the applicable law to guard your nonpublic personal information at all times. With respect to online privacy, we employ certain internet specific practices to maintain the security of your online sessions, including but not limited to firewall barriers, encryption and authentication procedures.
In the event that these policies change, RAM will provide clients with a sufficient amount of time to opt out of any disclosure provisions should that be desired. Nevertheless, RAM will provide a copy of its annual privacy notice to all clients upon inception of our investment advisory services. In addition, each of our active clients shall be provided with a copy of our privacy notice within ninety (90) days following the close of RAM’s fiscal year.