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Privacy Policy Guiding Principles The relationship between i2i Analytics LLC, its affiliates, and its clients is the most important asset of our firm. We strive to maintain your trust and confidence in our firm, an essential aspect of which is our commitment to protect your personal information to the best of our ability. We believe that all of our clients value their privacy, so we will not disclose your personal information to anyone unless it is required by law, at your direction, or is necessary to provide you with our services. We continue to apply the same privacy policies and practice to our former clients that we do to our existing clients. We have not and will not sell or give your personal information to any outside parties. This privacy policy applies to all consumers who have a relationship with i2i Analytics LLC and its affiliates by reason or merger or acquisition. Each affiliate of i2i Analytics LLC has its own separate privacy policies that are consistent with that of i2i Analytics LLC. Our privacy policy is subject to change. In the event that changes occur, you will be informed in accordance with applicable laws. Additionally, you will be provided with our privacy policy annually. For purposes of this policy, customer information means personally identifiable information about a consumer who has a relationship with i2i Analytics LLC. Accordingly, at i2i Analytics LLC we have adopted the following: Customer Information Security and Confidentiality We take a number of steps to ensure that customer information is adequately safeguarded. These steps include the following: Implementing a number of physical and electronic security features to prevent unauthorized access; Limited employee access to customer information; and Conducting periodic reviews of our computer systems, including security features. Additionally, our employees are required to acknowledge their responsibility to maintain the confidentiality of customer information. How We Collect Customer Information i2i Analytics LLC collects and maintains your personal information so we can provide investment management services to you. The types and categories of information we collect and maintain about you include: Information we receive from you to open an account or provide investment advice to you (such as your address, telephone number, and financial information); Information that we generate to service your account (such as account statements); Information that we may receive from third parties with respect to your account; and Information that we may receive about you from our affiliated companies. How We Disclose Customer Information In order for i2i Analytics LLC to provide investment management services to you, we may disclose the information we collect, as described above, in very limited instances, which include: Disclosures to companies - subject to strict confidentiality agreements – that perform services on our behalf (such as brokers); Disclosures to companies and Affiliates as permitted by law, including those necessary to service your account and relationship (such as providing information to custodians); Disclosure to our Affiliates only in accordance with the Fair Credit Reporting Act; To comply with law, regulations, or a court or government order or request; If you or any authorized person on the account gives us oral or written permission to do so; and In response to a request by an auditor or SEC examiner. For Vermont Residents Only The information-sharing practices contained in this notice are in accordance with federal law. Vermont law places additional limits on shoring information about Vermont residents, so long as you remain a Vermont resident. As such, we will not share information we collect about Vermont residents with companies outside of i2i Analytics LLC except: (1) With companies that perform marketing or other services on our behalf; (2) With the authorization or consent of the Vermont resident; or (3) As permitted or required by law. Additionally, we also will not share credit information about Vermont residents received from others within the i2i Analytics LLC family and its subsidiaries except with the authorization or consent of the Vermont resident. Customer Information Within the i2i Analytics LLC Family Please note that we are permitted under the Fair Credit Reporting Act to share your name, address, and facts about your transactions and experience with us among the i2i Analytics LLC Family. The entities within the i2i Analytics LLC family allow us to provide our customers with an array of financial services that include banking services, investment advisory services, trust services, and securities and brokerage services. Accordingly, these entities may share some information about you among themselves to provide you with an array of financial services that meet your needs. You may request us not to share your information among the i2i Analytics LLC Family other than that allowed under the Fair Credit Reporting Act. To do so, please submit your request in writing and mail to: First Republic Investment Management, 111 Pine Street, San Francisco, CA, 94111 Attn: Consumer Protection Department. Once we receive your request in writing, we will stop sharing this information as soon as reasonably possible for all accounts you hold individually and for all accounts you hold jointly with other persons. For accounts held by joint account holders, either individually or jointly with persons other than you, those joint account holders will need to submit a separate request. Customer Information About Former Customers We apply the same privacy policies and practices to our former customers that we do to our existing customers. Collected customer information is retained in accordance with Federal Law. Customer Information – Accuracy At i2i Analytics LLC, we recognize the importance of maintaining accurate customer information that is provided to you in various forms, including account statements and billing statements. If you ever notice that your information is inaccurate, please contact us. Upon your notification, we will correct any inaccuracies. Protecting Your Information There are a number of steps you can take to protect your information, including: 1) Before you reveal any personal identification information, find out how it will be used and whether it will be shared with others; 2) Pay attention to your billing cycles and follow up with creditors if your bills don't arrive on time; 3) Guard your mail from theft; 4) Deposit outgoing mail in post office collection boxes or at your local post office; and 5) Put passwords on your credit card, bank, and phone accounts. If you suspect that your personal information, including social security number or account information has been misappropriated to commit fraud or theft, please contact: 1) Your i2i Analytics LLC contact; 2) The fraud departments of each of the three major credit bureaus; 3) The creditors for any accounts that have been tampered with or opened fraudulently; and 4) Your local police or the police in the community where the theft took place. You should also contact the Federal Trade Commissions (FTC) at 1-877-IDTheft or via www.consumer.gov/idtheft. Privacy Policy Availability A copy of i2i Analytics LLC's Privacy Policy may be obtained by visiting our website or contacting any of our offices. Investments in securities are not FDIC insured, not bank guaranteed, and are subject to investment risks, including loss of principal. |
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