Our Commitment to Privacy
Wainwright Investment Counsel, LLC, WFS, LLC and Wainwright Capital Partners, LLC (collectively, “Wainwright” or “the Firm”) are committed to maintaining the confidentiality, integrity, and security of personal information about our current, former and prospective clients.
How and Why We Obtain Personal Information
Wainwright takes great care to protect personal information about you and when we use it, we do so with respect for your privacy. We may use personal information about you to service your relationship with Wainwright; facilitate transactions for your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; or to fulfill legal and regulatory requirements. Wainwright may collect public and non-public personal information about you from any of the following sources:
- Information you have provided to your representative on applications, forms or through personal communications (for example, name, address, Social Security number, birth date, assets and income);
- Transactional activity in your account (for example, trading history and balances);
- Information about your account at a non-affiliated financial services providers, such as fund managers;
- Other interactions with Wainwright or its employees (for example, discussions with our representative); and
- Other sources with your consent or with the consent of your representative (for example, your tax or legal advisors).
How We Protect Information About You
Wainwright considers the protection of personal information to be a foundation of client trust and a sound business practice. We employ physical, technical and administrative controls and we regularly adapt these controls to respond to changing requirements and advances in technology.
Wainwright has implemented safeguards in place which are reasonably designed to restrict access to nonpublic, personal information to those Wainwright Personnel who need to know that information in the course of their job responsibilities.
How We Share Information about You with Third Parties
Wainwright does not share personal information about our clients with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities:
- Unaffiliated service providers (for example, regulatory consultants or auditors, and other entities who may provide services at Wainwright’s direction);
- Government agencies, other regulatory bodies and law enforcement officials (for example, the Securities and Exchange Commission or the Internal Revenue Service); and
- Other organizations as permitted or required by law (for example, for fraud prevention).
Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by Wainwright.
Changes to Wainwright’s Policy
The privacy policies of Wainwright are reviewed annually. Wainwright reserves the right to change, modify, add, or remove portions of the notice as permitted by law at any time. Clients may want to review the notice periodically for changes. Please contact Wainwright at 617-531-3100 or compliance@winvcounsel.com if you have any questions about this notice.