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  D Squared Capital Management Privacy Policy

AT D SQUARED CAPITAL MANAGEMENT, YOUR PRIVACY IS CRITICAL TO US.  UNDER FEDERAL LAW YOU HAVE A RIGHT TO KNOW WHAT INFORMATION IS BEING COLLECTED ABOUT YOU AND HOW THAT INFORMATION WILL BE USED.

D SQUARED CAPITAL MANAGEMENT, LLC (“D SQUARED”) is a registered investment advisory firm that offers planning and advisory services to clients.  The following describes how D SQUARED handles your personal information, and what steps we take to protect your privacy.  We do not disclose your personal information to any unaffiliated third party for marketing purposes.  If you close your account with us or otherwise become a former client, we will treat your non-public, personal financial information as described in this policy.

Accessing Information
Access to customer information is authorized for D SQUARED’s business purposes only.  It is based on our need to know such information to assist you in locating products or services to fit your needs, to conduct our business, and to comply with applicable regulations and industry standards of conduct.  D SQUARED requires employees who have access to customer information to protect it and keep it confidential.

Collecting Information to Conduct Business
As authorized by you, D SQUARED collects information about you to help serve your financial needs, provide customer service, offer products or services, ascertain customer suitability, and fulfill legal and regulatory requirements.  The type of information you provide D SQUARED varies according to the products or services you request, and may include:

  • Information included on your application and related forms (such as name, address, Social Security number, net worth, and income);1
  • Information about your relationship with your broker (such as products or services purchased, account balances, and payment history);
  • Information from visitors to D SQUARED’s web site (such as that provided through online forms, site visitorship data and online information collecting devices, known as “cookies”).

Security Standards
D SQUARED continues to assess new technology to evaluate its ability to provide additional protection of your personal information.  We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your non-public personal information.

Sharing Information with Non-Affiliates
In the course of conducting business, we may disclose some or all of the previously described information about you to non-affiliated third parties, as allowed by law, for the purpose of:

• Effecting, administering, or enforcing a transaction that you request or authorize and to otherwise provide customer service or account maintenance;
• Responding to a subpoena, or to comply with an inquiry by a government agency or regulator, or to otherwise prevent fraud or rule violations; and
• Performing services for us or on our behalf.

1 If any of your information changes, please let your advisory associate know, so that your records may be updated.