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Federal law now requires distribution to clients of a formal
privacy policy statement. Our privacy policy is set forth below.
Simply put, we do not sell your personal information to anyone.
In addition, we do not disclose your personal information to any
affiliated or third party except where required for the efficient
administration of your account or where required by law. If you
have any questions, please feel free to call us at 909-445-1291
or email us at contact@gouldasset.com.
Categories of Non-Public Personal Information We Collect
• In completing documents to retain Gould Asset Manager LLC
(“Gould”) as an investment adviser or consultant, or to
invest in a fund managed by Gould (a “Fund”), you provide
us with such personal information as name, address, social security
number or tax identification number, the value of your assets, your
income level, investment experience, and investment objective.
• In discussing with us your investment objectives or the
suitability of an investment in a Fund, you may supply us with detailed
information about your investment portfolio, income levels and sources,
insurance and estate planning issues, potential liabilities and
obligations, and relationships with other professionals, among other
things.
• In the course of your transactions with a Fund, we may receive
from you information regarding relationships you have with banks
and/or other financial institutions.
Categories of Non-Public Personal Financial Information
that We Disclose and Recipients of Such Information
• Information about our clients is disclosed to certain third
parties under agreements with such parties, as necessary, in the
regular course of administrating client accounts, as described more
fully below.
• We are required to supply to a Fund’s prime broker
(the custodian of the Fund’s assets) a copy of your executed
Fund subscription signature page upon each investment you make into
a Fund.
• We are required to supply to the Fund’s outside accounting
firm your name, address, social security number (or tax identification
number), and the dates and amounts of your transactions in a Fund
for the purposes of preparing periodic Fund accounting statements
and annual tax return information.
• For each Fund, we are required to file a tax return annually
with the Internal Revenue Service which includes information about
you and your investment in the Fund.
• We may disclose or report personal information in limited
circumstances where we believe in good faith that disclosure is
required or permitted under law, for example, in the case of a court
order or a request from securities regulators.
• We will, upon your request, disclose information about your
investment in a Fund to such entities as your CPA, stockbroker,
and/or legal advisor.
• In each of the cases above, we do not disclose any more
information to these entities than is necessary for the performance
of their functions. Our agreements with third-party recipients of
personal information require that each such recipient treat such
information confidentially.
• As applicable and necessary in the conduct of our business,
we will make the disclosures listed above with respect to persons
who are no longer clients.
Protecting the Confidentiality, Security and Integrity of
Non-Public Personal Information
• We follow prudent business practices in protecting the confidential
personal information you provide us. These include physical, electronic,
and procedural safeguards.
Other Privacy Matters
• We do not sell personal information to anyone.
• We provide prospective and existing clients with a copy
of this privacy policy statement.
• We will make disclosures required under the Fair Credit
Reporting Act only to the extent required by law.
• We will notify you of our privacy policy annually. If we
modify this policy, we will notify you promptly.
• We recommend that you treat information about your account
confidentially.
• We ask that you notify us promptly of any change in your
personal information or any errors in the information that we have.
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