Privacy Policy

Privacy Policy of Beechwood Capital Advisors, Inc (“Beechwood”)

This policy will be communicated to all clients upon request for engagement of services to be rendered by Beechwood and is otherwise available upon request by any party interested in doing business with Beechwood.

Your Privacy Is Important To Beechwood

In the course of serving you as an individual client Beechwood may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

This Policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information, and the steps that we take to safeguard the information to protect your privacy. As used throughout this Policy, the term Beechood refers to Beechwood Capital Advisors, Inc. and its affiliates.

The Sources of Information

The personal information we collect about you comes primarily from the materials you submit to Beechwood during the course of your relationship with us. We may also collect information about your transactions and experiences with Beechwood. In addition, Beechwood may, as part of its due diligence, obtain additional information about you, such as your credit history and other publicly available information as well as utilize outside vendors who conduct investigations for a fee as part of its obligation to “know your client” (“KYC”) pursuant to legal and regulatory requirements

Finally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g., recording of telephone calls and monitoring e-mails). In these circumstances, the information is not accessed on a continuous or routine basis but it may be used for compliance or security purposes.

The Information We Have About You

  • Your name and contact details;
  • Your role/position/title and area of responsibility; and
  • Certain other information needed as part of a typical engagement.

Of course, you are not required to supply any of the information that we may request. However, failure to do so may result in our being unable to provide services to you. While we make every effort to ensure that all information we hold about you is accurate, complete and up to date, you

can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.

Our Use of Your Personal Information

We may use your personal information to:

  • Administer, operate, facilitate and manage your relationship and/or account with Beechwood. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;
  • Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship;
  • Provide you with information, recommendations or advice concerning products and services offered by Beechwood; and
  • Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

If your relationship with Beechwood ends, Beechwood will continue to treat your personal information, to the extent we retain it, as described in this Policy.

Disclosures of Your Personal Information Within Beechwood

In order to provide efficient and reliable services, and to improve product and service options available to you, more than one party or person within Beechwood may be given, or given access to, your personal information. When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within Beechwood is provided below under Information Security: How We Protect Your Privacy.

Disclosures of Your Personal Information to Third Parties

Beechwood does not disclose your personal information to third parties, except as described in this Policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with Beechwood, including those that provide professional, legal, or accounting advice to Beechwood. Non-affiliated companies that assist Beechwood Capital Advisors in providing services to you are required to maintain the confidentiality of such information to the extent they receive it, and to use your personal information only in the course of providing such services and only for the purposes that Beechwood dictates.

We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners, or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations, for instance, when responding to a subpoena or similar legal process, to protect against fraud, and to otherwise cooperate with law enforcement or regulatory authorities, or with organizations such as exchanges and clearinghouses.

You should know that Beechwood Capital Advisors will not sell your personal information.

Information Security: How We Protect Your Privacy

Beechwood is committed to implementing the highest standards of information security to protect the privacy and confidentiality of your personal information. We limit access to your personal information to authorized Beechwood employees or agents and, as described above in Disclosures of Your Personal Information to Third Parties, our service providers are held to stringent standards of privacy. We also maintain physical, electronic, and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure. Some of the other central features of our information security program are:

  • The use of specialized technology such as firewalls;
  • Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
  • Implementing controls to identify, authenticate and authorize access to various systems or sites;
  • Protecting non-public communications through encryption or other means; and
  • Providing Beechwood personnel with relevant training and continually updating our security practices in light of new risks and developments in technology.

Other Privacy Policies or Statements; Changes to Policy

This Policy provides a general statement of the ways in which Beechwood protects your personal information. This Policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information.

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