Compass Advisors, LLC (the “Firm”) considers the confidentiality, integrity and security of our clients’ information and records essential to maintaining trust and superior service.
The Firm collects certain non-public information concerning our clients and prospective clients, including (i) information provided on an account application which contains identifying information, such as name, address, tax identification numbers, existing investments and investment profiles, (ii) account numbers and balance information, (iii) trade orders and confirmations, and (iv) information that the Firm may receive from a consumer reporting agency.
To the extent that the Firm collects certain non-public personal information about current and prospective clients, we shall not disclose such information to any person or entity, other than (i) among our employees, subsidiaries and affiliates, (ii) as is required to carry out the Firm’s advisory services, (iii) to comply with regulations applicable to our business or (iv) as compelled by law.
The Firm does not sell client information to any third party, nor does the Firm exchange client information with third parties for marketing purposes, except as may be specifically consented to by the client under an applicable investment advisory services agreement, or pursuant to a separate written agreement or authorization.
The Firm has implemented internal policies and procedures to protect the privacy of client information it collects. The Firm adheres to these internal policies and procedures both during and after termination of the client relationship. The Firm will not disclose any information regarding former clients other than (i) as necessary to transfer the client’s account to another investment adviser or financial institution, (ii) as directed by the client, or (iii) as otherwise set forth herein.