Stonebridge Capital Management NW, LLC
Our Commitment to Your Privacy: Protecting clients’ privacy is of paramount importance to Stonebridge Capital Management NW, LLC. (the “Firm” or “Advisor”). It is Stonebridge Capital’s policy that no private client financial information obtained by the Firm is sold or made available to third parties except that:
- Third parties may be used by the Firm to assist in the management or maintenance of client accounts (such as a custodian, broker or bank).
- Client information may be released to client’s accountancy, legal and other third party representatives at client’s direction;
- Client information may be released in accordance with applicable laws and regulations.
The Firm will not share non-public personal information about its clients with non-affiliated third parties without prior client consent, except for specific purposes described below. This notice explains the Firm’s collection, use and safeguarding of client information.
How Stonebridge Capital Gathers Information: In connection with providing clients with investment management services, the Firm may obtain information about its clients from the following sources:
- Client agreements and other information that clients provide to the Firm, whether in writing, in person, by telephone, electronically or by any other means. This information may include a client’s name, address, phone number, email address, social security number, employment information, income, and investment experience;
- Personal tax returns provided by the client;
- Transactions on a client’s behalf. This information may include the client’s account balances, positions, investment interests and history;
- Consumer reporting agencies. This information may include account information; and
- Public sources.
Sharing Information with Non-affiliated Third Parties: Advisor only discloses non-public client information to non-affiliated third parties when it is believed necessary for the Firm’s provision of services to you or as required or permitted by law, such as:
- If you request or authorize the disclosure of the information;
- To provide client account services or account maintenance;
- To respond to a subpoena or court order, judicial process, law enforcement or regulatory authorities;
- To perform services for the firm or on its behalf to develop or maintain proprietary trading or other software;
- To help prevent fraud;
- To comply with federal, state or local laws, rules and other applicable legal requirements.
Stonebridge Capital Management does not make any disclosure of client non-public personal information to other companies who may want to sell their products or services to you. For example, the Firm does not sell client lists and the Firm will not sell client names to catalogue companies.
Opt Out Provision: If, at any time in the future, it is necessary to disclose any client personal information in a way that is inconsistent with this policy, Stonebridge Capital Management will give its clients advance notice of the proposed disclosure so that they will have the opportunity to opt out of such disclosure. The Firm believes that sharing client private information under the circumstances noted above is either mandated by law or necessary for the Firm to conduct its business and to best service client accounts. Clients desiring to opt out of the above disclosures should contact the Firm immediately to terminate its agreement with you and arrange for you to transfer your account. If, at any time in the future, it is necessary to disclose any of client personal information in a way that is inconsistent with this policy, Stonebridge Capital Management will give clients advance notice of the proposed disclosure so that they will have the opportunity to opt out of such disclosure.
Our Security Practices and Information Accuracy: Stonebridge Capital Management takes steps to safeguard client information. Access to the personal and account information of clients is restricted to its employees and agents for business purposes only. The Firm maintains physical, electronic and procedural safeguards to guard your personal information. Additionally, the Firm has internal controls to keep client information as accurate and complete as possible. If you believe that any information about you is not accurate, please contact the Firm.