This notice informs you of the privacy practices of Gurtin Fixed Income Management, LLC dba Gurtin Municipal Bond Management (“Gurtin”) and applies to all non-public personal information of current, prospective, and former clients (collectively, “Clients,” “You,” and “Your”). Our relationship with our clients is Gurtin’s most important asset. We understand that our clients have entrusted us with their private information, and we are committed to maintaining the confidentiality, integrity, and security of that information.
INFORMATION WE COLLECT
Gurtin will obtain access to non-public personal information through each client’s account application, investment management agreement, and correspondence with Gurtin representatives and through transactions with Gurtin. This information may include:
• Name and address
• E-mail address
• Phone number
• Social security number
• Taxpayer identification number
• Account balance
• Investment Activity
• Accounts at other institutions
In addition, we may collect non-public information from the following sources:
• Information we receive on Subscription Agreements, Mutual Fund account documents, Managed Account Agreements, and other Subscription and Account Opening Documents
• Information we receive in the course of establishing a customer relationship including, but not limited to, applications, forms, questionnaires, and data through our website
• Information about your transactions with us, our affiliates, or others
• Shared Personal Information
HOW WE SAFEGUARD YOUR INFORMATION
We take our responsibility to protect the privacy and confidentiality of your information very seriously. We maintain physical, electronic, and procedural safeguards to store and secure information about you from unauthorized access, alteration, and destruction, including by restricting access to non-public personal information to those employees responsible for the management and servicing of the Account or to whom access is necessary for another proper business purpose.
HOW WE SHARE INFORMATION WE COLLECT
We may disclose the information that we collect, as described above, in the following circumstances: Gurtin may disclose non-public personal information to affiliates and to non-affiliated third parties, such as brokers and custodians, as necessary, to facilitate the acceptance and management of our relationship. We may also disclose non-public personal information to companies Gurtin hires to help administer its business and to affiliates and other financial institutions with whom we have joint marketing
arrangements. In addition, non-public personal information may be released to the appropriate client or to such client’s authorized agent or representative, if compelled to do so by law, or in connection with any government or self-regulatory organizational request or investigation, or as otherwise permitted by law.
INFORMATION AUTOMATICALLY COLLECTED ON OUR WEBSITE