Guiding Principles
The relationship between Lilliothea Investment Management, LLC and our clients is the most important
asset of our firm. We strive to maintain your trust and confidence in our firm, an essential aspect of which
is our commitment to protect your nonpublic personal information to the best of our ability. We believe that
all of our clients value their privacy, so we will not disclose your nonpublic personal information to anyone
unless it is required by law, at your direction, or is necessary to provide you with investment management
services. We have not and will not sell your nonpublic personal information to anyone. This privacy policy
replaces all previous statements of our client privacy policy and may be amended at any time. We will keep
you informed of changes as required by law.
Personal Information That We Collect, Maintain, And Communicate
Lilliothea Investment Management, LLC collects and maintains your nonpublic personal information so we
can provide investment management services to you. The types and categories of nonpublic personal
information we collect and maintain about you includes:
- Information we receive from you to open an account or provide investment advice to you (such as
your name, home address, telephone number, marital status, social security number and financial
information including any information contained in the account application);
- Information that we generate to service your account (such as account balances, parties to
transactions, trade tickets and account statements); and
- Information that we may receive from third parties with respect to your account (such as trade
confirmations from brokerage firms).
Your Client Information Is Shared Only In Limited Ways and Is Carefully Controlled
In order for us to provide investment management services to you, we use or share client information in a
limited and carefully controlled manner, which include:
- Disclosures to companies as permitted by law, including those necessary to service your account
(such as providing account information to brokers and custodians);
- Disclosures to regulatory agencies as permitted by law, including the Securities and Exchange
Commission, the Department of the Treasury and state securities commissions. These agencies may make official requests from time to time regarding client accounts and trading activity, to
which we are obligated to respond; and
- Disclosures to companies – subject to strict confidentiality agreements – that perform services on
our behalf (such as our technology consultants who assist us in maintaining our computer
systems).
How We Protect Your Personal Information
To fulfill our privacy commitment at Lilliothea Investment Management, LLC we have instituted firmwide
practices to safeguard your nonpublic personal information. These include:
- Adopting policies and procedures that put in place physical, electronic, and other procedural
safeguards that comply with federal regulations to keep your nonpublic personal information safe.
- Limiting access to nonpublic personal information to those employees who need it to perform
their job duties.
- Requiring third parties that perform services for us to agree by contract to keep your nonpublic
personal information strictly confidential.
- Protecting nonpublic personal information of our former clients to the same extent as our current
clients.
We Will Work Together With You To Protect The Security Of Your Client Information and To
Keep Your Information Accurate And Current
We strive to keep your client and financial information accurate. If you believe that our records are
incorrect or out of date, please notify us as soon as possible. We will make any necessary corrections
quickly.
You can help to maintain your privacy by taking such precautions as protecting your account numbers and
passwords and not disclosing confidential information to unknown callers.
Privacy is a partnership. Because privacy matters, we pledge to work together with you to protect and
control the security of your confidential financial information.
