Privacy policy

PRIVACY POLICY

At Toroso Investments, LLC (“Toroso”) protecting your privacy and the security of your personal information is one of our top priorities.  We honor our relationship with you as a sacred trust and are committed to the responsible management, use and protection of your personal information.  This notice provides information about how we collect, share, and protect your personal information.  Please read this notice carefully.

Toroso may collect non-public information about you from the following sources: (1) Information that we receive about you on applications, agreements, or other forms; (2) Information that you give us orally; (3) Information about your transactions with us or others; and (4) Information that you submit to us in written correspondence, including emails and other electronic communications.  Information from these sources generally includes, but is not limited to, information on your personal background, investment objectives, risk tolerances, financial situation, investment holdings, financial transactions, and account numbers.

We pledge to maintain the confidentiality of your personal information in our possession, in accordance with the disclosures in this privacy notice.  Toroso does not sell its current or former customers’ non-public personal information to any third parties and does not disclose any non-public personal information about our current or former customers without their authorization, except that we may disclose information as follows: (1) Toroso may disclose information to non-affiliated third-parties in connection with our performance of the services we have agreed to provide you, such as to process transactions or to otherwise maintain your account; (2) Toroso may disclose information if specifically required to do so by judicial or regulatory processes; and (3) Toroso may disclose any information that we have collected about you to non-affiliated third-parties that perform services for us on our behalf, such as our professional advisors (e.g., consultants, accountants, and attorneys),  vendors we hire to provide support for our services, and solicitors that market our services.  These third-parties, however, act on our behalf and are contractually obligated to keep the information we provide them confidential and to use the information only for the purposes authorized.

Any disclosure of information in a document that has been completed and submitted by you to Toroso to facilitate a business relationship between you and a third party provider (i.e., banker, account custodian, insurance company, etc.) will automatically be considered as having been authorized by you with respect to the non-affiliated third party service provider.

Each individual or party affiliated with Toroso is aware of this Privacy Policy, and has agreed to comply with it.  Members of the firm have access to the nonpublic personal information of our clients to the extent that it is necessary for them to perform their responsibilities owed to Toroso.  Toroso maintains physical, electronic, and procedural safeguards to guard your information.

As required by federal law, Toroso will provide notice to its customers of its Privacy Policy annually.  Toroso reserves the right to modify this policy at any time, but in the event that there is a change, Toroso will promptly inform its customers of that change.