Regulation S-P requires investment advisor firms to protect the privacy of customer information. In situations where a financial institution does disclose customer information to non-affiliated third parties, other than permitted or required by law, customers must be given the opportunity to opt out or prevent such disclosure. D’Arcy Capital Management LLC does not share or disclose customer information to non-affiliated third parties except as permitted or required by law.
D’Arcy Capital Management LLC is committed to safeguarding the confidential information of our clients. We hold all personal information provided by you in the strictest confidence and it is our objective to protect the privacy of all clients. Except as permitted or required by law, we do not share confidential information about clients with non-affiliated parties. If there is a change in this policy, D’Arcy Capital Management LLC will provide you with written notice and you will be provided an opportunity to direct us whether such disclosure is permissible.
To conduct regular business, we may collect personal information from sources such as:
- Information reported by you on applications or other forms you provide to us
- Information about your transactions implemented by us or others
- Information developed as part of analysis or investment advisory services
To administer, manage, service and provide related services for client accounts, it is necessary for us to provide access to customer information within the firm and to non-affiliated companies with whom we have entered into agreements. To provide the utmost service, we may disclose the information below regarding customers and former customers, as necessary, to companies to perform certain services on our behalf.
- Information we receive from you on applications (name, social security number, address, assets, etc.)
- Information about your transactions with us or others (account information, payment history, parties to transactions, etc.)
- Information concerning investment advisory account transactions
- Information about your financial products and services transaction with us
Since we share non-public information solely to service your accounts, we do not disclose any non-public personal information about our customers or former customers to anyone except as permitted by law. However, we may also provide customer information outside of the firm as required by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas.