Further, pursuant to Regulation S-P, “Privacy of Consumer Financial Information”, which requires all investment advisory firms to issue an annual notice to its clients relating to the privacy of consumer financial information, we would like to inform you that EII Capital Management, Inc. receives non-public personal information about its clients from the following sources:
- Information we receive on agreements, applications or other forms, and
- Information about transactions with EII or others.
EII believes that all of its clients value their privacy, and will not disclose personal information unless it is required or permitted by law, at your direction, or is necessary to provide you with our services.
In order for EII to provide investment management services, EII does disclose personal information in very limited instances, which include:
- Disclosures to companies – subject to strict confidentiality standards – that perform services on our behalf (such as technology consultants and software providers who assist us in maintaining our computer systems);
- Disclosure to companies as permitted by law, including those necessary to service your account (such as providing account information to brokers and custodians); and
- Disclosure to federal and state regulators as required by law.
EII considers customer privacy to be a fundamental aspect of the relationship with its clients. Furthermore, EII is committed to maintaining the confidentiality, integrity, and security of current, prospective and former clients’ personal information. Policies have been developed and implemented to protect this confidentiality, while allowing client needs to be served. EII restricts access to its clients’ personal and account information to those employees on a “need to know” basis in order to provide our products and services to clients. EII maintains physical, electronic and procedural safeguards to secure non-public personal information. EII will update its policies and procedures when necessary to ensure that its clients’ privacy is maintained and that EII conducts business in a way that fulfills its commitment to all of its clients.