Our Commitment to Your Privacy
Staley Capital Advisers, Inc. (“Staley Capital,” the “firm,” “we,” or “us”) respects your privacy and is committed to securing the confidentiality and integrity of your personal information. Our Privacy Notice discloses how we collect, use, share and safeguard the non-public personal information of our prospective, current and former clients (“client information”).
Information We Collect
In connection with our investment management business, Staley Capital obtains non-public personal information from our clients including but not limited to:
- Full name, date of birth, Social Security number, tax identification number, addresses.
- Financial account numbers, account balances, payment instructions.
- Income, assets, securities holdings, investment objectives, and tax sensitivities.
- Account maintenance information such as responses you provide to account applications, questionnaires, legal documents and email communications.
How We Use Your Information
Staley Capital uses your information to perform the following activities in furtherance of our business relationship with you:
- Establish written investment advisory contracts.
- Review your investment objectives.
- Open, update and maintain accounts.
- Provide investment advice and recommendations.
- Execute securities transactions, process cash transfers or withdrawals.
- Deliver account statements, reports, and client communications.
- Comply with applicable legal and regulatory requirements including anti-money laundering obligations.
Information Sharing Practices
Staley Capital only shares your information with certain authorized third-party vendors used by our firm for daily operational and account support services such as:
- Qualified custodians and broker-dealers.
- Portfolio analytics, management and reporting platforms.
- Technology, compliance, and auditing service providers.
These vendors may have access to non-public information about our clients, so we are required to ensure they have adopted appropriate data privacy and cybersecurity policies, incident response plans and controls as required by applicable law.
Staley Capital does not sell or share any client information for marketing or research purposes.
Information Retention
Client information is retained and disposed of in a secure manner pursuant to our data safeguarding and recordkeeping policies and procedures. Even if a client relationship ends, we are required to maintain this information for regulatory purposes.
Because Staley Capital shares client non-public information for the purposes of servicing client accounts, clients are not offered an opt-out option.
Safeguarding Client Information
Information security is an integral part of our firm culture. We maintain comprehensive physical, administrative and technical safeguards throughout our business that are reasonably designed to protect nonpublic information from unauthorized access, use, or disclosure. All firm employees must adhere to the policies and standards set forth in our code of ethics and compliance policies to ensure responsible and lawful handling of such information.
Employees are also subject to mandatory security awareness training and certify their understanding and compliance with firm policies on an annual basis.
Questions?
Staley Capital distributes this Privacy Notice to new clients and annually thereafter. If any of the information in this notice changes or becomes inaccurate, we will promptly notify you with the updated document.
For questions about this notice or if you would like more information about our firm’s security policies, please contact our Chief Compliance Officer at 888-256-4743 or 412-261-6892.