Polaris Capital Partners is committed to protecting our clients’ privacy. We make the following pledge to our clients:
1. We will limit the collection and use of personal information to the minimum we require to administer our business and provide superior service to you. This information includes the data we receive from you on customer applications, forms completed on our website or other forms, such as your name, address, social security number, assets, income, investment objectives and experience and information about your transactions conducted through our firm, such as your account balance and net profit or loss. In accordance with Commodity Futures Trading Commission (“CFTC”) Rule 160.13, we may disclose all of the information we collect, as described above, to companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements.
2. We may disclose nonpublic personal information about our clients and former clients as permitted under CFTC Rules 160.14 and 160.15. The law permits us to share this information with companies that perform services for your account, such as brokers who execute your futures transactions. The law also permits us to share this information with third parties acting on behalf of you, such as your IRA custodian or trustee.
3. We may disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to comply with legal requirements or with legal process served on us, to protect and defend our rights or property, or in urgent circumstances to protect the personal safety of any individual.
4. We restrict access to nonpublic personal information about you to those employees, agents and service providers who need to know that information to provide services to you. We maintain physical, electronic and procedural safeguards that comply with federal standards to safeguard your nonpublic personal information.
5. We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act); we do not collect any personal information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 18 years old or older.
6. In the event that we sell all or part of our business, we will include provisions in the selling contract requiring the purchaser to treat your personally identifiable information in the same manner required by this Online Privacy Statement (including any amendments to this Online Privacy Statement).