Privacy Policy

At Conifer Financial Services and its related companies (collectively, "Conifer"), preserving and protecting the privacy and confidentiality of nonpublic personal and financial information collected from our clients ("Nonpublic Information") is vital to our business. This policy provides information regarding our practices surrounding the collection and handling of Nonpublic Information and how it applies to current as well as former clients.

The Information We Collect

In the course of business, clients may share with Conifer Nonpublic Information such as addresses, tax identification numbers, bank account information and asset holdings. Clients may also share with Conifer Nonpublic Information relating to their own underlying clients on whose behalf they manage money or funds or process information. This privacy policy applies equally to the Nonpublic Information Conifer receives about underlying clients. Conifer collects Nonpublic Information from applications, reports, instructions, website usage and other sources both written and electronic. Conifer may also receive this similar Nonpublic Information from third parties that assist Conifer in administering client accounts and processing transactions on clients' behalf. Conifer limits the collection, use and retention of client information to what will help us deliver contracted services, administer our business, and to meet applicable laws and regulations.

Use and Disclosure of Information

Conifer does not disclose any Nonpublic Information about our clients, former clients or prospective clients to any party except as permitted by law.

To the extent permitted by law and as authorized by a client, such as in a services agreement between Conifer and a client, Conifer may use a client's Nonpublic Information and share it with certain designated third parties in order to facilitate accounting, administrative and other related services with third parties. In such cases, Conifer provides the third party with only the information necessary to carry out its contracted responsibilities and only for that purpose.

On occasion, Conifer may be required under certain laws and regulations to provide information about its clients' accounts and transactions to governmental agencies, self-regulatory organizations, industry associations and similar bodies in order to fulfill legal and regulatory requirements; for example, in response to a subpoena, to prevent fraud, and to comply with rules of, or inquiries from, industry regulators.

Under no circumstances does Conifer sell Nonpublic Information to unauthorized parties or disclose such information to marketing companies.

Safeguarding the Information

Conifer restricts access to a client's Nonpublic Information to those Conifer employees and third parties who need to know the information to provide clients with contracted for services. Conifer maintains physical, electronic, and procedural safeguards to protect the security and confidentiality of Nonpublic Information. Our own policies and procedures have been developed to protect the confidentiality of client information and to help achieve compliance with relevant rules and regulations. We hold our employees accountable for complying with those policies, procedures, rules and regulations.


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