Legal Notice

This Privacy Notice is for the clients and investors of Greiner-Higgins Associates LLC

The maintenance of the privacy of your personal information is one of the company’s top concerns.  In order to provide the most excellent services to you, we must keep certified information about you that we have gathered from your account applications or other forms that you have filled out, or from any transactions that you have performed with us, including your communications with us.  However, our policy does not divulge personal information that we collect from you to third parties except only when allowed by law or requested by you.  Also, we limit access to non-public personal information to employees who need to get certain information to provide services to you.  

We uphold physical, electronic and procedural protections that meet or exceed federal standards to shield your nonpublic personal information.  Should you have any questions regarding our Privacy Policy, you are most welcome to contact us. Furthermore, we reserve the right to revise, amend and improve our privacy policy but we will not do so without notice to you.

In accordance with Regulation S-P recently adopted by the US Securities and Exchange Commission and regulations by other exchanges, we are required by law to inform you annually of our policies regarding privacy of customer information.  

We at Greiner-Higgins Associates LLC understand that your privacy is important to you, and we are committed to keeping your personal information confidential. This Privacy Notice provides general information on how we use and protect your personal information.

Types of nonpublic personal information we collect from you:

  • Information we receive from you on account applications or other forms, such as your name, address, Social Security number, and information about your financial status;
  • Information about your transactions with us, our affiliates, or others; and
  • Information you provide us through your account inquiries by mail, telephone or over the internet.

 

Parties to whom we disclose your non-public personal information:

We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as required or permitted by law. Permitted disclosures include, for example, providing information to our employees and, in limited situations, to affiliated and unrelated third- party financial service providers who need to have that information in order to assist us in providing services to you.

 

Greiner-Higgins Associates LLC ’s Privacy Policy and Procedures:

As stated in our Code of Ethics, Greiner-Higgins Associates LLC is committed to preserving the confidentiality of its customer relationships:

Confidentiality is a fundamental principle of the investment management business.

Greiner-Higgins Associates LLC Employees must maintain the confidential relationship between the Corporation and each of its Clients. Confidential information, such as the identity of Greiner-Higgins Associates LLC Clients and the extent of their account relationship, must be held inviolate by those to whom it is entrusted and must never be discussed outside the normal and necessary course of the Corporation's business. To the extent possible, all information concerning Greiner-Higgins Associates LLC Clients and their accounts shall be shared among Greiner-Higgins Associates LLC Employees on a strictly need-to-know basis.

 

In order to protect the confidentiality of our customers’ nonpublic personal information:

  • Greiner-Higgins Associates LLC has designated its Compliance Officer as the person responsible for supervising the firm’s privacy policy.
  • Greiner-Higgins Associates LLC maintains procedural safeguards that are designed to ensure the security
    and confidentiality of customer records and information.
  • Greiner-Higgins Associates LLC will disclose a customer’s nonpublic information only to those affiliated and unrelated third-party financial service providers that are involved in processing and servicing the customer’s account, as permitted by law, or upon written instructions received from the client.