Our commitment to your privacy
Ascendant Alternative Strategies (“AAS”) has a policy of protecting the confidentiality and security of information AAS collects about its customers. AAS will not share non-public personal information about you (“Information”) with third parties without your consent, except for the specific purposes described below. This notice describes the Information AAS may gather and the circumstances under which AAS may share it.
Collection of Information
AAS collects and uses the Information to deliver superior service to you. Such service includes maintaining your accounts with AAS, processing transactions requested by you and administering AAS’ business. AAS gets most Information directly from you when you apply for, access and use financial products and services offered by AAS — whether in person, by telephone or electronically. AAS may verify this information or get additional information, including creditworthiness or credit history, from other financial institutions or service providers with whom you may have authorized to provide such information and/or consumer reporting agencies, verification services or public sources. This Information may relate to your finances, employment, avocations or other personal characteristics, as well as interactions with or through AAS or others.
Disclosure of Information
AAS may not disclose Information about you to affiliates or nonaffiliated third parties except as permitted by law or consented to by you. For example, Information may be disclosed:
- In connection with AAS’ administration and operations and AAS’ products and services,
- To AAS’ brokers, attorneys, accountants, auditors, administrators or other service providers;
- To respond to a subpoena or court order, judicial process or governmental or regulatory inquiry (including regarding money laundering);
- In connection with a proposed or actual sale, merger, or transfer of all or a portion of AAS’ business;
- To protect or defend against fraud, unauthorized or violative transactions (such as money laundering violations), lawsuits, claims or other liabilities; and
- To assist in offering AAS-affiliated products and services to you.
The foregoing may include responses to inquiries for purposes of compliance with anti-money laundering and anti-terrorist due diligence, disclosure or reporting requirements. Except in those specific, limited situations, without your consent, AAS does not make disclosures of Information to other companies who may want to sell their products or services to you. For example, AAS does not sell customer lists and will not sell your name to a catalogue company. It is AAS’ general policy to require all third parties, other than your broker, that are to receive any Information to sign strict confidentiality agreements.
To Whom This Policy Applies
Protection of Information
AAS maintains physical, electronic and procedural safeguards that comply with federal standards to protect customer information. AAS restricts access to the personal and account information of customers to those employees who need to know that information in the course of their job responsibilities.
Access to and Correction of Information
If you desire to review any file AAS may maintain regarding your Information, please contact your broker. If you or your broker notifies AAS that any Information is incorrect, AAS will review it. If AAS agrees, AAS will correct its records. If AAS does not agree, you may submit a short statement of dispute, which AAS will include in future disclosures of the disputed Information. Information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available.