Privacy Policy

Adrian Day Asset Management

At Adrian Day Asset Management (“ADAM”), protecting your privacy and safeguarding your personal information is very important to us. We have always valued the trust our clients have placed in us and are committed to the confidentiality and protection of our clients’ personal information. Please take a moment to review our Privacy Policy, as described below.

Gathering Information

We treat the information we gather about you in a confidential manner. ADAM collects information about you to help us serve your financial needs, administer and update accounts, reduce fraud and other risks, provide customer service, offer new products or services, and fulfill legal and regulatory requirements. Any collection of personal information is to support our normal business operations and service your account.

In order to service your account, ADAM may collect nonpublic, personal information from you as well as from other sources. The sources and the information collected may include:

• Information you provide to us or to our affiliated entities such as address, Social Security number, birth date, email address, net worth, assets, and income.
• Information regarding your transactions with us, our affiliates or others, such as products or services purchased, account balances, trading history, and payment history, as well as information from information service companies and consumer reporting agencies, such as your transactions or credit relationships with unaffiliated third parties.
• Information from other unaffiliated third parties including employers, associations, benefit plan sponsors, and other institutions or non-financial services providers, such as mutual fund companies, investment firms, third party administrators, clearing firms, and other third parties who assist in providing account maintenance or client service to the client account(s).

Sharing Information

We may disclose any of the nonpublic, personal information that we collect about you as required to conduct our business. The firm reserves the right to disclose or report personal information in limited circumstances where the firm believes in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities, to perform necessary credit checks or collect or report debts owed to the firm, or to protect the firm’s rights or property. We may share information about our clients with our affiliates, unaffiliated financial or non-financial services providers, such as mutual fund companies, investment firms, any ADAM affiliated company, third party administrators, clearing firms, and other third parties who assist in providing account maintenance or client service to your account(s). We also may share your information with regulators and law enforcement organizations, or in response to a subpoena or discovery request, as permitted or required by law. We do not sell your nonpublic, personal information identified above; however we may share or disclose this information to companies for marketing purposes. You have the right to “opt- out” of such disclosure, as described at the bottom of this Privacy Policy. All companies with whom we share information are contractually obligated to comply with strict standards regarding security and confidentiality, and the information provided can be used only for the sole purpose of providing the service(s) we have requested the company to perform, or would be expected to be performed based upon such third party’s lines of business.

Safeguarding Privacy

ADAM recognizes the need to prevent unauthorized access to the information we collect, including information held in electronic format. ADAM authorizes access to your nonpublic, personal information only to personnel who require that information to serve you. We maintain physical, electronic, and procedural safeguards to guard your nonpublic, personal information to ensure that we comply with our own policy, industry practices, and federal and state regulations. Should you decide to terminate your relationship with us, you can be assured that your information will continue to be treated according to the policies and practices as described in this privacy notice.

Opting-out

If you do not want ADAM to share your information as described above, you have the right to opt-out of such disclosure. If you wish to opt-out, now or at any time in the future, please contact ADAM Compliance at: 410-224-2037.

Adrian Day Asset Management
P.O. Box 9024106, San Juan, PR 00902 • T: 410-224-2037