Privacy Policy
Clavis Capital Management, LLC is an investment adviser ("RIA") registered with the New Jersey Bureau of Securities and a commodity trading advisor ("CTA") registered with the Commodity Futures Trading Commission ("CFTC") and a member of the National Futures Association ("NFA"). We are required by law to inform you of our policies regarding the privacy of client information, and to tell you how we collect, share, and protect your personal information. Federal law gives you the right to limit some, but not all, sharing of your personal information.
Your accounts are held directly in your own name at your prime broker, which serves as custodian, executing broker, and futures commission merchant. This Prime Broker maintains its own privacy notice covering the information it collects from you directly. This notice describes our practices.
TYPES OF NONPUBLIC PERSONAL INFORMATION (NPI) WE COLLECT
We collect nonpublic personal information about you that you provide to us, or that we obtain with your authorization, in connection with providing advisory services to you. This may include:
➢ Name, address, telephone number, and email address;
➢ Date of birth and Social Security number or taxpayer identification number;
➢ Identification documents collected to satisfy our anti-money-laundering obligations;
➢ Financial account numbers and account balances;
➢ Sources of income, net worth, and investment experience;
➢ Investment objectives, risk tolerance, and other information relevant to the suitability of our services; and
➢ Information about your transactions with us and with your custodian.
PARTIES TO WHOM WE DISCLOSE INFORMATION
We do not sell, rent, or otherwise disclose your personal information to anyone for marketing purposes. We have no affiliates, and we do not participate in any joint marketing arrangements with other financial companies.
We do disclose nonpublic personal information where it is necessary to provide advisory services to you and to operate our business. We may share your information:
➢ For everyday business purposes — such as to effect, administer, and enforce the transactions you request or authorize;
➢ With nonaffiliated third parties that perform services on our behalf, as described in the following section;
➢ With your consent or at your direction;
➢ To protect against or prevent fraud, unauthorized transactions, or other liability;
➢ With persons acting in a fiduciary or representative capacity on your behalf;
➢ With our attorneys, accountants, and auditors; and
➢ With regulators and self-regulatory organizations, and in response to subpoenas, court orders, and legal investigations, as permitted or required by law.
The categories of nonaffiliated third parties to whom we disclose your information are:
➢ Your custodian, executing broker, and futures commission merchant;
➢ Our independent third-party administrator, which calculates account performance; and
➢ Technology, compliance, and information security service providers.
INFORMATION SHARED WITH SERVICE PROVIDERS
We disclose nonpublic personal information to nonaffiliated third parties that perform services for us or functions on our behalf. The categories of information disclosed for this purpose are the same categories described above — information you provide to us and information about your transactions. The categories of firms with which we have contracted for these purposes are:
➢ Custody, brokerage, and clearing firms;
➢ Fund administration and performance reporting firms;
➢ Technology, data storage, and communications providers;
➢ Compliance consulting firms; and
➢ Information security consulting firms.
Each such firm is bound by a written agreement that prohibits it from disclosing or using your information for any purpose other than carrying out the services for which we disclosed it.
PROTECTING CONFIDENTIALITY OF CURRENT AND FORMER CLIENT’S INFORMATION
We restrict access to your personal information to those employees, officers, and agents who need that information in order to provide services to you. We maintain physical, electronic, and procedural safeguards designed to protect your nonpublic personal information, including computer safeguards, secured files, and controlled access to our offices. We maintain a written information security program and review it periodically.
When you are no longer our client, we continue to apply the same limitations on disclosure of your information that are described in this notice. We retain your records for the periods required by applicable law and regulation, and we disclose information about former clients only as described above — for example, to regulators, in response to legal process, or with your consent.
FEDERAL LAW GIVES YOU THE RIGHT TO LIMIT SHARING – OPTING OUT
Federal law allows you to limit certain sharing of your nonpublic personal information — in particular, sharing with affiliates for their everyday business purposes and sharing with affiliates or nonaffiliates who would use your information to market to you. We have no affiliates, and we do not share your information with anyone for marketing purposes, so this sharing does not occur at our firm.
You may nonetheless direct us at any time not to disclose your nonpublic personal information to nonaffiliated third parties, other than disclosures that are necessary to service your account or that are permitted or required by law. To do so, contact us in writing. We will honor your direction as soon as reasonably practicable after we receive it. Your direction will remain in effect until you revoke it in writing. State law and individual companies may give you additional rights to limit sharing.
DEFINITIONS:
➢ Nonpublic personal information — personally identifiable financial information you provide to us, information about your transactions with us, and information we otherwise obtain about you in connection with providing our services.
➢ Affiliates — companies related by common ownership or control. They can be financial and non-financial companies. Clavis Capital Management, LLC has no affiliates.
➢ Nonaffiliates — companies not related by common ownership or control. They can be financial and non-financial companies.
➢ Joint marketing — a formal agreement between nonaffiliated financial companies that together market financial products or services to you. We do not engage in joint marketing.
Please call if you have any questions. Your privacy, our professional ethics, and the ability to provide you with quality financial services are very important to us.
CLAVIS CAPITAL MANAGEMENT, LLC
560 SYLVAN AVENUE SUITE 3160 ENGLEWOOD CLIFFS, NJ 07632
201-377-2050 - info@claviscap.us