At Alpha Growth Management, safeguarding your privacy is among our highest priorities. As an investment advisor firm, we collect and utilize nonpublic personal information (“NPI”) to provide financial services to prospective and current shareholders of Alpha Alternative Assets Fund and other financial institutions in an efficient and convenient manner. This notice provides an overview of the types of NPI we collect, how we safeguard your privacy, and our data sharing practices. All NPI is handled according to this policy.
WHAT IS NPI? WHAT TYPES OF NPI DOES ALPHA GROWTH MANAGEMENT COLLECT, AND FROM WHOM DO WE COLLECT IT?
Nonpublic personal information (NPI) is confidential personal information about you that we obtain in connection with providing financial services. We generally access nonpublic personal data about you from the following sources:
- Information we receive from you (e.g., name, address, date of birth, etc.) in account applications, service agreements, correspondence, and other forms;
- Information about your transactions with us (e.g., income, investment objectives, asset values, etc.), or other parties to transactions such as account custodians, banks, etc.; and
- Information about you from unaffiliated financial service providers and others to verify your identity or to help us identify other products or services that may be of interest to you.
HOW IS YOUR NPI UTILIZED?
We utilize your NPI to facilitate transactions with our firm or with authorized, unaffiliated service providers, such as account custodians chosen by mutual agreement, and other entities that require this information to provide services to you. We may also share your NPI with other unaffiliated service providers you have authorized to access it for conducting business with you or on your behalf (e.g., trustees, lawyers, accountants, etc.). Disclosure of your NPI to these parties is unrestricted and made possible through your agreement and explicit consent, as permitted and required by law. The NPI we collect may be transferred to or stored by our firm or our service providers, as permitted by law.
Additionally, service providers must agree to keep your information confidential.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
Internally, we use physical, electronic, and procedural safeguards to protect your NPI. These safeguards include measures to secure your information before, during, and after the termination of our services. We limit access to your NPI to our employees and others who need it to perform our services. Additionally, we ensure that access to your NPI is strictly restricted to our authorized service providers who need it solely to deliver our services.
OTHER INFORMATION SHARING
As previously mentioned, we may disclose your NPI to unaffiliated service providers you have authorized. We may also disclose it to regulatory authorities and law enforcement agencies. For instance, we may disclose your NPI to our attorneys, accountants, auditors, or to regulatory authorities in connection with the assessment of our compliance with industry standards. Alpha Growth Management reserves the right to share your NPI with unaffiliated service providers as outlined herein and as permitted by law. In all permitted sharing events, service providers must agree to maintain the confidentiality of your NPI and are prohibited from using or sharing it for any other purpose.
We also adhere to state-specific privacy requirements. An overview of these sharing practices is as follows:
- CALIFORNIA RESIDENTS: We will not share the information we collect about you with nonaffiliated third parties, except as permitted by law. We will not disclose your creditworthiness to our affiliates, except as permitted by California law, unless you authorize us to make such disclosures.
FUTURE POLICY REVISIONS
This privacy policy notice may be updated to reflect changes in our practices, procedures, or regulatory requirements concerning the collection, use, and sharing of your NPI. You will receive written notification of revisions or changes to this policy. If you have questions regarding our privacy policy, please do not hesitate to write or email us at:
Alpha Growth Management LLC
1615 South Congress Avenue, Suite 103
Delray Beach, Florida 33445
E-mail: info@alphagrowthmgt.com