Privacy policy:
Recognition of a Client's Expectation of Privacy
You regard your personal information as yours, and so do we. Because we do not sell or share your information with third parties not associated with services or activities of Spyglass Investment Management, there is no need for you to tell us not to share your personal information with non-affiliated third parties.
Collection, Retention, and Use of Client Information
We collect and use various types of information to service your accounts and better understand your needs. We collect personal information about you from the following sources:
Information we receive from you on applications or other forms
Information about your transactions with us, our affiliates, or others
Disclosure of Information to Nonaffiliated Third Parties
As the Firm shares nonpublic information solely to service our client accounts, we do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law.
For example, this may include a disclosure in connection with a subpoena or similar legal process, a fraud investigation, or an audit or examination. We may also share information if you initiate a request for us to share information with an outside party or if the information is provided to help complete a client-initiated transaction.
Information Safeguarding
Spyglass Investment Management will internally safeguard your nonpublic personal information by restricting access to only those employees who provide products or services to you or those who need access to your information to service your account. In addition, we will maintain physical, electronic and procedural safeguards that meet federal and/or state standards to guard your nonpublic personal information.