Our Commitment to Our Clients
Turner Capital Investments, LLC (TCI) is committed to protecting the privacy and security of our clients’ information. Our clients trust us with personal and financial information. We honor that trust by handling all information carefully and sensibly. This notice outlines the standards we use for protecting information.
TCI continually reviews, updates and improves our security standards and procedures to help us protect confidential information. To protect client personal information from unauthorized access and use, we use security measures that comply with federal law. These include:
- computer safeguards, secured files and buildings;
- regular training of staff on privacy and information security, and on their obligations to protect client information;
- limiting employee access to client information to those who have a business reason to know; and
- secure destruction of client information when required to do so.
Information Required from TCI Clients
As a Registered Investment Advisor, TCI may collect personal information, including:
- Social Security Number
- Account Transactions
- Risk Tolerance
- Other personal, private financial information
This information is critical to our management of investment strategies. When a client discontinues the use of our services, we will continue to hold certain information as described in this notice and pursuant to applicable rules and regulations. When appropriate, material that contains confidential client information is carefully and securely destroyed
What is our policy relating to former customers?
If you decide to close your account(s) or become an inactive client, we will adhere to the privacy policies and practices as described herein. We reserve the right to change this policy at any time and you will be notified if any material changes occur.
TCI does not share client information with outside parties who may wish to market their products to clients. We may disclose the information we collect to non-affiliated third parties that are acting on our behalf, or as permitted or required by law, including:
- Companies that perform support services for TCI, such as brokerage services and asset and accounting reconciliations.
- Non-affiliated third parties such as attorneys, accountants, auditors, and persons or consulting firms who are evaluating TCI's business or are assessing TCI's compliance with industry standards.
- Companies that help TCI market products and services to our clients, or conduct surveys or provide marketing research.
- Government entities, courts, or other entities (in response to subpoenas and other legal processes), or those with whom TCI clients have requested us to share information.
TCI enters into contractual agreements with all nonaffiliated third parties that prohibit them from disclosing or using the information other than to carry out the purposes for which we disclose the information.
No personal information, including that regarding a client’s account or the terms of their management agreement with TCI will be disclosed, except with the client’s express permission, as permitted or required by law, or as necessary to provide services.
In all cases, TCI will require those firms to adhere to strict standards of security and confidentiality. These firms will not be permitted to release, to use, or to transfer any of our clients’ information to any other party for their own purposes. In all cases, TCI recognizes the great responsibility it has on behalf of TCI clients to maintain the security and the confidentiality of client personal information.
TCI offers a variety of financial products and services that may be of interest to clients. TCI believes it is beneficial to educate clients on these products and services. It is recognized, however, that clients might have preferences about how TCI staff may contact them. Clients may also have questions about how TCI will handle specific circumstances regarding their personal information as well as the security and availability of this information.
To discuss these or any other questions, or to provide feedback, please contact us at email@example.com.
Turner Capital Investments, LLC.
9442 Capital of Texas Highway N
Arboretum Plaza One Suite 500
Austin, TX 78759
Revised June 1, 2014