Collection of Client Information
ShoreBridge collects nonpublic personal information about its clients from the following sources:
– Information ShoreBridge receives from clients in any Subscription Agreement, or Investment Management Agreement, or other forms or agreements completed by clients; and
– Information about clients’ transactions with ShoreBridge, information about entities advised by ShoreBridge or its affiliates, or information ShoreBridge receives from third parties in the servicing of clients’ accounts.
Disclosure of Client Information
ShoreBridge may share information about its clients with affiliated and unaffiliated persons, including service providers or other third parties that: (i) provide business services to or on behalf of ShoreBridge; (ii) facilitate the processing of transactions that clients may request; or (iii) assist ShoreBridge in servicing client accounts or offering products or services to clients.
ShoreBridge may also disclose a client’s information where required by law or to protect ShoreBridge’s rights or property, such as in an audit, or to ShoreBridge’s attorneys or other professionals. ShoreBridge may disclose information to client’s attorneys, brokers, accountants, and bankers with whom clients have an established relationship.
Security of Client Information
ShoreBridge maintains office security to ensure that client information is not placed at unreasonable risk of disclosure. ShoreBridge restricts access to nonpublic information about its clients to those employees who need to know the information to provide products and services. ShoreBridge maintains physical, electronic, and procedural safeguards that protect its clients’ nonpublic personal information. ShoreBridge’s agreements with unaffiliated third parties require that strict confidentiality be maintained for clients’ nonpublic personal information. Federal and state securities regulators may review ShoreBridge’s records and clients’ records as permitted by law. Personally identifiable information about clients will be maintained while a client relationship continues and for the subsequent period of time that records are required to be maintained by law. After that time the information may be destroyed. The destruction of such information will be done in a manner reasonably designed to protect nonpublic client information.
Procedures to Opt Out of Disclosure