Dynamique Capital Advisors LLC (“Dynamique”, “firm”, “we”, or “our”), as a Registered Investment Adviser, is covered under the definition of a “financial institution” under the Gramm-Leach-Bliley Act and the Securities and Exchange Commission’s (“SEC”) Privacy of Consumer Financial Information Rule (“Regulation S-P”). The staff of Dynamique realizes that providing personal information is an act of trust. Dynamique values its clients’ trust and confidence.
We will never sell or share the nonpublic personal information obtained from or in reference to clients. All information provided by clients to Dynamique and its staff, and information and advice furnished to clients by us, shall be treated as confidential and shall not be disclosed to affiliated or unaffiliated third parties, except as permitted or directed by clients with written authorization, by application to facilitate the investment services offered by the firm via an unaffiliated financial services provider, or as required by any rule, regulation or law.
Commitment to Your Private Information. Dynamique is committed to safeguarding the confidential information of its clients. Dynamique holds all personal information provided by clients in the strictest confidence and it is the objective of the firm to protect the privacy of all clients. Except as permitted or required by law, Dynamique does not share confidential information about clients with non-affiliated parties. It is our policy to restrict access to all current and former clients' information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/non-affiliated entities who need to know that information in order to provide products or services in furtherance of the client's engagement of Dynamique.
Why We Collect and How We Use Information. To conduct regular business, Dynamique may collect personal information from sources such as information:
- reported by the client on applications or other forms the client provides to the firm;
- about the client’s transactions implemented by the firm or others;
- developed as part of financial plans, analyses, or investment advisory services; and
- to administer, manage, service, and provide related services for client accounts.
It is necessary for Dynamique to provide access to client information within the firm and to non-affiliated companies, with whom we have entered into agreements. The disclosure of information contained in any document completed by the client for processing and/or transmittal by Dynamique to facilitate the commencement / continuation / termination of a business relationship between the client and/or between Dynamique and a non-affiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, record keeper, insurance company, etc.), including, but not limited to, information contained in any document completed and/or executed by the client in furtherance of the client's engagement of Dynamique (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding non-affiliated third-party service provider.
Sharing Information with Other Companies Permitted Under Law. Dynamique may disclose the client's information:
- to individuals and/or entities not affiliated with Dynamique, including, but not limited to the client's other professional advisors and/or certain service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, record keeper, proxy management service provider, etc.) that may be recommended or engaged by Dynamique in furtherance of the client's engagement of Dynamique;
- required to do so by judicial or regulatory process; or
- otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations.
Finally, Dynamique strives to only recommend financial services providers that share its privacy policies; however, clients are encouraged to request each specific firm’s written policy for review.
Information Security. Dynamique maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients' nonpublic personal information. Through this policy and its underlying procedures, Dynamique attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.
We maintain client records in a controlled environment and records are only available to authorized persons of the firm who have a need to access client information in order to deliver advisory services or respond to client requests. Our policy to protect client information extends beyond the termination of the Engagement Letter or Client Agreement.
Children. Our company website is not directed to children under the age of 18 years. By accessing and using our website, you represent and warrant that you are at least 18 years old.
Contact Us. Clients are encouraged to discuss any questions regarding privacy policies and procedures directly with Luka Erceg, Chief Compliance Officer of Dynamique Capital Advisors, LLC. Contact information: firstname.lastname@example.org or +1.858.947.4260.