Our website address is: https://northboundwealth.com.

Privacy Policy

Our commitment to privacy

Northbound Wealth Management Investments and the Northbound Wealth Management Funds are committed to maintaining the confidentiality, integrity, and security of personal information about our current and prospective customers. In this policy personal information means information about an individual that is collected or maintained for business purposes and by which the individual can be identified.

Please note that certain details of this policy may depend on whether you deal with us through an investment professional, directly as an individual investor, or whether Northbound Wealth Management provides services to your employer or plan sponsor.

The privacy policies of Northbound Wealth Management Investments and the Northbound Wealth Management Funds are reviewed annually. Our printed and online notices are then updated to reflect any changes.

  

Northbound Wealth Management Investments privacy policy

How and why we obtain personal information

Northbound Wealth Management takes great care to protect personal information about you and when we use it, we do so with respect for your privacy. We may use personal information about you to service, maintain, and protect your account; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; or to fulfill legal and regulatory requirements. Northbound Wealth Management may collect public and non-public personal information about you from any of the following sources:

  • You or your representative on applications or forms (for example, name, address, Social Security number, birth date, assets and income)
  • You or your employer or plan sponsor if Northbound Wealth Management provides them with recordkeeping and/or benefits advisory services (for example, payroll, human resources, or benefits information)
  • Transactional activity in your account (for example, trading history and balances)
  • Other interactions with Northbound Wealth Management (for example, discussions with our customer service staff, information you enter into our websites, or when you enroll in our authentication services)
  • Information from consumer reporting agencies (for example, to assess your creditworthiness for margin products)
  • Information from other third-party data services (for example, to verify your identity and to better understand your product and service needs)
  • You or your representative regarding your preferences (for example, your choice of electronic statement delivery, or the screen layout you specify if you use our Internet sites)
  • Other sources with your consent or with the consent of your representative (for example, from other institutions if you transfer positions into Northbound Wealth Management)

Please note that information by which you cannot be identified (for example, anonymous or aggregated information) is not considered personal information and therefore is not subject to this privacy policy.

 

How we protect information about you

Northbound Wealth Management considers the protection of personal information to be a foundation of customer trust and a sound business practice. We employ physical, electronic and procedural controls and we regularly adapt these controls to respond to changing requirements and advances in technology.

At Northbound Wealth Management, we restrict access to personal information to those who require it to develop, support, offer and deliver products and services to you.

 

How we share information about you with third parties

Northbound Wealth Management does not share personal information about our customers with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities:

  • Unaffiliated service providers (for example, printing and mailing companies, securities clearinghouses, marketing service providers, and other entities who may provide services at Northbound Wealth Management’s direction)
  • Government agencies, other regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions)
  • Other third-parties, with your consent or as directed by your representative (for example, if you use Northbound Wealth Management as a financial reference in applying for credit with another institution or if you use an external aggregation website or service that you have provided permission to access your Northbound Wealth Management financial account on your behalf)
  • Other organizations as permitted or required by law (for example for fraud prevention or to respond to a subpoena)

Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by Northbound Wealth Management.

Based on the nature of your relationship with Northbound Wealth Management, we may exchange information with other third parties as described below:

  • If Northbound Wealth Management provides workplace services to your employer or plan sponsor, such as payroll, human resources or benefits advisory and/or recordkeeping services, Northbound Wealth Management may exchange any information received in connection with such services with your employer or plan sponsor or others they may authorize.
  • If you conduct business with Northbound Wealth Management through your investment professional, we may exchange information we collect with your investment professional or with others they may authorize.
  • If you transact business through Northbound Wealth Management’s life insurance companies, we may validate and obtain information about you from an insurance support organization. The insurance support organization may further share your information with other insurers, as permitted by law. We may also share medical information about you to learn if you qualify for coverage, to process claims, to prevent fraud, or otherwise at your direction, as permitted by law.

 

How we share information about you within Northbound Wealth Management

We may share personal information about you with various Northbound Wealth Management corporate affiliates including internal service providers which perform, for example, printing, mailing, and data processing services.

Additionally, if you interact with Northbound Wealth Management directly as an individual investor (including joint account holders) or if Northbound Wealth Management provides services to your employer or plan sponsor, we may exchange certain information about you with Northbound Wealth Management financial services affiliates, such as our brokerage and insurance companies, for their use in marketing products and services as allowed by law.

Information collected from investment professionals’ customers is not shared with Northbound Wealth Management affiliates for marketing purposes, except with your consent and as allowed by law.

 

Your digital privacy

Privacy, security, and service in Northbound Wealth Management’s online operations are just as critical as in the rest of our business. We use firewall barriers, encryption techniques, and authentication procedures, among other controls, to maintain the security of your online session and to protect Northbound Wealth Management accounts and systems from unauthorized access.

When you interact with us by using our websites, online services or mobile applications that are owned and controlled by Northbound Wealth Management Investments (“our digital offerings”), Northbound Wealth Management manages personal information in accordance with all of the practices and safeguards described previously.

When you use our digital offerings, we may collect technical and navigational and location information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on our digital offerings. We use this information for a variety of purposes, such as maintaining the security of your session, facilitating site navigation, improving Northbound Wealth Management website design and functionality, and personalizing your experience. Additionally, the following policies and practices apply when you are online.

Cookies and similar technologies

Northbound Wealth Management and our third-party service providers may use cookies and similar technologies to support the operation of our digital offerings. Cookies are small amounts of data that a website or online service exchanges with a web browser or application on a visitor’s device (for example, computer, tablet, or mobile phone). Cookies help us to collect information about users of our digital offerings, including date and time of visits, pages viewed, amount of time spent using our digital offerings, or general information about the device used to access our digital offerings. Northbound Wealth Management cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie, or if you delete cookies from your device, you may experience some inconvenience in your use of our digital offerings. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device, or your online preferences.

Both Northbound Wealth Management and third-party service providers we hire may use cookies and other technologies, such as web beacons, pixel tags, or mobile device ID, in online advertising as described below.

Advertising on Northbound Wealth Management Digital Offerings

Northbound Wealth Management advertises on its own digital offerings (including our mobile applications), and when we do, we may use information about your relationship with us, such as the types of accounts you have, to tailor advertisements and communications about Northbound Wealth Management and third-party products and services that may be of interest to you.

We may also use third-party service providers to help us determine which Northbound Wealth Management products and services may be of interest to you. These service providers may collect information about your activity on Northbound Wealth Management digital offerings using cookies and other technologies to analyze, for example, pages visited, search engine referrals, browsing patterns, and responses to advertisements and promotions. Such service providers may only collect and use such information for purposes specified by Northbound Wealth Management and not for their own purposes.

Advertising on Non-Northbound Wealth Management Digital Offerings

Northbound Wealth Management also advertises our products and services on digital offerings not affiliated with Northbound Wealth Management and we contract with third-party advertising companies to display these ads. These third-party advertising companies may use cookies and similar technologies to collect technical and web navigational information, such as device type, browser type, Internet protocol address, and pages visited.

Northbound Wealth Management and these third-party online advertising companies may use the data collected, along with other information we have about you and your Northbound Wealth Management relationships, to serve relevant ads to you. The advertisements may be relevant to your interests, as determined by your activity on Northbound Wealth Management and non-Northbound Wealth Management websites. These advertisements are known as “interest-based advertisements”.

You may opt-out of receiving interest-based advertisements from online advertising companies by clicking on the AdChoices icon (which appears on all Northbound Wealth Management interest-based ads) and following the opt-out instructions. For more information about interest-based advertising please see http://www.networkadvertising.org/managing/opt_out.asp.

Connecting with Northbound Wealth Management on social media platforms

Northbound Wealth Management provides experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. We may collect information you provide by interacting with us via social media, such as photographs, opinions, or social media account ID. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is also subject to the terms of use and privacy policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.

Northbound Wealth Management’s mobile® apps

Northbound Wealth Management Mobile® applications (“apps”) allow you to access your accounts, trade securities, move money, and access news and research using wireless or mobile devices. Our privacy practices apply to any personal information or other information that we may collect through the apps.

Third Party websites and applications

Non-Northbound Wealth Management websites and mobile applications (for example, social media platforms) are not subject to Northbound Wealth Management’s privacy policy. You may visit the individual sites for additional information on their privacy practices and advertising opt-out instructions.

Protecting children’s privacy online

Northbound Wealth Management websites are not directed to individuals under the age of thirteen (13). Northbound Wealth Management does not intentionally collect information on Northbound Wealth Management websites from those we know are under 13, and we request that these individuals do not provide personal information through the sites.

 

Additional information

If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers.

Northbound Wealth Management offers several options for accessing and, if necessary, correcting your account information. You can review your information using your statements, or through our automated telephone or Internet services. You may also write or call us with your request for information. If you transact business through Northbound Wealth Management’s life insurance companies, you are entitled to receive, upon written request, a record of any disclosures of your medical record information. If we serve you through an investment professional, please contact them directly. Specific Internet addresses, mailing addresses and telephone numbers are listed on your statements and other correspondence.

The Northbound Wealth Management Investments privacy policy is provided on behalf of:

  • Northbound Wealth Management, LLC
  • Other companies owned by Northbound Wealth Management Investments using the Northbound Wealth Management name to provide financial or payroll services to customers

 

Northbound Wealth Management Funds privacy policy

Protecting your personal information is an important priority for the Northbound Wealth Management Funds. The Funds’ privacy policy is designed to support this objective. The Funds collect non-public personal information concerning you in the following ways:

  • Information provided by you or your representative on applications or other forms furnished to the Funds or through other interactions that you or your representative have with the Funds
  • Information arising from your investments in or accounts with the Funds
  • Information the Funds receive from a consumer reporting agency

The Funds employ physical, electronic, and procedural controls to safeguard your information. For example, the Funds authorize access to your personal and account information only for personnel who need that information in order to provide products or services to you.

The Funds do not disclose any non-public personal information about you, except as permitted by law. For example, the Funds have entered into a number of arrangements with Northbound Wealth Management Investments to provide for investment management, distribution and servicing of the Funds.

If you decide to close your account, the Funds will continue to adhere to the privacy policies and practices as described in this notice.

Please read the Northbound Wealth Management Funds Privacy Policy in conjunction with the Privacy Policy for the Northbound Wealth Management Investments companies of which you are also a customer.

The Northbound Wealth Management Funds Privacy Policy is provided on behalf of the Northbound Wealth Management Investments family of mutual funds

Effective October 2020

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