Your privacy is very important to us. This notice is provided by Alpha RIA LLC (Alpha, the firm, us, we, or our). This Privacy Notice sets forth our policies with respect to non-public personal information about our investors and clients and prospective and former investors and clients. For purposes of this notice, the terms “customer” or “client” include both (i) individuals who have a continuing client relationship with the firm (e.g., by having an investment advisory contract with the firm or by holding an investment product through the firm) and (ii) individuals who provide nonpublic personal information to the firm, but who do not have a continuing relationship with the firm (e.g., an individual who provides such information in deciding whether to become a client, whether or not the individual establishes a continuing relationship with the firm).
These policies apply to investors in our SMA portfolios and other clients and may be changed at any time, provided a notice of such change is given to you. We recognize and respect the privacy expectations of our clients. We provide this notice to you so that you will know what kinds of information we collect about our customers and the circumstances in which that information may be disclosed to third parties who are not affiliated with us. If you are a corporate customer (including, for these purposes, legal arrangements such as personal investment companies, trusts, or limited partnerships) that provides us with personal information on individuals connected to you for any reason in relation to your business with us, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.
Collection of Your Information
We collect the following nonpublic personal information about our customers:
• Information from the customer
• Information about the customer’s transactions with us or our affiliates
• Information about the customer’s transactions with non-affiliated third parties.
Information from these sources can include:
• Account Applications and other forms, which may include a customer’s name, address, passport information, social security number, and
information about a customer’s investment goals and risk tolerance
• Account History, including information about the transactions and balances in a customer’s account
• Correspondence, written, telephonic, or electronic, between a customer and Alpha or service providers to Alpha.
Among other sources, we may collect this information through Internet web sites
Disclosure of Your Information
We may disclose all of the information described above to certain third parties who are not affiliated with us under one or more of the following
As Authorized – if you request or authorize disclosure of the information.
As Required by Law – for example, to cooperate with regulators or law enforcement authorities.
As Otherwise Permitted by Law – to organizations with which we are not affiliated, if doing so is necessary to provide the service you are
buying (“Service Providers”) – for example, sharing information with companies that maintain, process, or service your accounts or financial products
and services or effect, administer, or enforce your transactions is permitted. Among other activities, we may share information with broker-dealers in
order to execute your trades or with custodians that hold securities on your behalf. We may also share your personal information with organizations who
provide services to our firm, including lawyers, auditors, accountants, brokers, AML service providers, tax information exchange service providers, or
other back office service providers. We believe that sharing of information for these purposes is essential to providing you with necessary or useful
services with respect to your accounts.
Security of Your Information
We require our Service Providers:
• to maintain policies and procedures designed to assure only appropriate access to information about our customers
• to limit the use of information about our customers to the purposes for which the information was disclosed, or as otherwise permitted by law
• to maintain physical, electronic and procedural safeguards that comply with federal standards to guard non-public personal information about
We will adhere to the policies and practices described in this notice regardless of whether you are a current or former client of Alpha
Before we may disclose non-public personal information about any consumer (including any customer) to a non-affiliated third party other than a Service
opt-out notice. The opt-out notice would describe our planned disclosures and give customers a reasonable opportunity to decline permission to make
those disclosures. Because we do not disclose non-public personal information to non-affiliated third parties, other than Service Providers or pursuant to
the exceptions, we are not required to provide opt out notices.
Within Alpha, access to information about you is restricted to those employees who need to know the information to service your account. Our
employees are trained to follow our procedures to protect your privacy and are instructed to access information about you only when they have a
business reason to obtain it. We use physical, electronic and procedural safeguards to keep your information secure.
California Consumer Rights
Under California law, residents of California have the right to know what personal data is being collected about them, know whether their personal data is
being sold or disclosed, opt out of the sale of their personal data, access their personal data, request deletion of their personal data, and have equal
service and price even if they exercise their privacy rights. To exercise those rights, the California resident should call +1 (212) 933-9301. We do not sell
any customer data.
as otherwise required or permitted by law without giving you an opportunity to instruct us not to.
If you have questions regarding these policies, please contact us by writing to Alpha RIA LLC, 40 Wall Street, 28th Floor, New York, New York 10005,
Attention: Chief Compliance Officer, emailing email@example.com or by calling +1 (212) 933-9301. Your privacy is very
important to us. These policies apply to our clients and may be changed at any time, provided a notice of such change is given to you.
This policy composes a part of our Form ADV Part 2A, which is available at https://files.adviserinfo.sec.gov/IAPD/Content/Common/crd_iapd_Brochure.aspx?BRCHR_VRSN_ID=777254 and upon emailed request to firstname.lastname@example.org. This version is reproduced here for your convenience.
Effective January 1, 2022
Our Commitment to Protect your Privacy
Alpha maintains physical, electronic, and procedural safeguards that comply with federal standards such as the Gramm-Leach-Bliley Act (GLBA) and the European Union’s (EU) General Data Protection Regulation (GDPR) to protect its clients’ nonpublic personal information (Personal Information) as defined under GLBA, and to the extent applicable, “personal data” as defined under the GDPR. For the purposes of this policy, “personal data” means information that can directly or indirectly, identify an individual person and specifically includes, but is not limited to, a client’s name, address, birthdate, social security number, bank account number(s), tax identification number, other government-issued identification numbers; other forms and documents a client sends to us; and any other information about a client’s transactions with us.
This policy shall also include “Personal Data” that we collect on our firm’s website (Site), such as cookies. Through this policy and its underlying procedures, Alpha attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.
You can find out more about Alpha at our Site or by contacting us using the information in the ‘contact us’ section.
How and What Type of Personal Information We Collect
To conduct regular business, Alpha may collect personal information from sources such as:
- Personal Information reported by the client on applications or other forms the client provides to the firm
- Personal Information about the client’s transactions implemented by the firm or others
- Personal Information developed as part of financial plans, analyses or investment advisory services
- Personal Information collected on our Site such as cookies.
To administer, manage, service, and provide related services for client accounts, it is necessary for Alpha to provide access to customer information within the firm and to nonaffiliated companies, with whom the firm has entered into agreements with. To provide the utmost service, the firm may disclose the information below regarding customers and former customers, as necessary, to companies to perform certain services on the firm’s behalf.
- Information Alpha receives from the client on applications (name, social security number, address, assets, etc.), from third parties authorized to share your information with us, from Cookies, or from publicly available information
- Information about the client’s transactions with the firm or others (account information, payment history, parties to transactions, etc.)
- Information concerning investment advisory account transactions
- Information about a client’s financial products and services transaction with Alpha
In addition to the above, other specific types of Personal Information that Alpha collects includes, but is not limited to: birthdate, bank account number(s), tax identification number, other government-issued identification numbers; other forms and documents a client sends to Alpha, as well as information to create a client’s online account.
How We Use Your Personal Information
Alpha will only use your Personal Information for the purpose of providing investment advisory services to you, including, but not limited to: (1) to monitor, audit, evaluate and otherwise administer our services; (2) to communicate with you; (3) in an effort to protect against fraud and identity theft; (4) comply with applicable legal requirements, relevant industry standards, contractual obligations, and our policies and terms; and (5) for other purposes as required or authorized by law, including other purposes for which you have provided your consent and our legitimate interests.
Lawful Basis to Process Your Personal Information
To lawfully process your Personal Information, Alpha retains one or more of the following lawful bases: (1) your voluntary consent in connection to providing you with Alpha’s investment services; (2) as necessary in order to fulfill certain contractual obligations; (3) as necessary to comply with applicable rules, laws, and regulations; and (4) as necessary in connection to the legitimate interests of our firm and/or a third party.
Your Rights and Limits on Sharing
In terms of your rights, to the extent permitted by applicable law, you may request: (1) to have your Personal Information corrected; (2) to opt out of receiving marketing communications at any time; (3) to file a complaint with an applicable government regulator; (4) to access the Personal Information Alpha holds about you; (5) to restrict or object to the processing of your Personal Information, or request that your Personal Information is erased; (6) to receive a copy of the Personal Information you have provided to Alpha, in a structured, commonly used format (known as “data portability”); (7) have a copy of your Personal Information provided to you or another controller where technically feasible; (8) to withdraw your consent to Personal Information that you provided to us voluntarily, or otherwise consented to its use.
To the extent U.S. Federal laws apply to your Personal Information, you have the right to limit only: (i) sharing for affiliates’ everyday business purposes; (ii) affiliates from using your Personal Information to market to you; and (iii) sharing for non-affiliates to market to you. U.S. state laws and individual companies may give you additional rights to limit sharing.
Alpha may share your Personal Information for its everyday business purposes such as maintaining your account(s) or responding to court orders and legal investigations. For these types of purposes, you cannot limit sharing. We do not use your Personal Information to market our services to you. Moreover, Alpha does not share your Personal Information with “non-affiliated” companies for marketing purposes or for “joint marketing” purposes as those terms are defined under applicable U.S. Federal law.
As discussed above, we will endeavor to ensure your Personal Information is kept accurate, complete, up to date, and relevant. Please let us know if any of your details change. If you feel your Personal Information is not accurate, complete, or up to date, please notify us and we will take reasonable steps to ensure it is corrected. Additionally, you have the right to know what kind of information we collect and retain about you, to have reasonable access to it, and to request a copy of it. You can contact us to request this information using the details listed below.
In accordance with the foregoing, Alpha may take steps to verify your identity before granting you access to your Personal Information.
How We May Share Your Personal Information with Third Parties
How Long We Retain Your Personal Information
To the extent permitted by applicable law, Alpha retains your Personal Information for the period necessary to serve the purposes for which Alpha obtained it. Alpha may also retain your Personal Information beyond such period in accordance with applicable laws, regulations, or another lawful basis, including but not limited to, compliance with our contractual obligations, legal obligations, regulatory obligations, legal claims, or another legitimate interest.
How We Maintain Accuracy of Your Personal Information
Alpha will endeavor to ensure your Personal Information is kept accurate, complete, up to date, and relevant. Please let Alpha know if any of your details change. If you feel your Personal Information is not accurate, complete, or up to date, please notify us and we will take reasonable steps to ensure it is corrected. You can contact us in the Contact Us section below.
To the extent GDPR applies, Alpha is the data controller for this policy located at the address below.
Additional Personal Information about Our Site
For additional information about our Site policies, please refer to the section of this Site titled Terms & Conditions.
Changes to this Policy
Alpha will provide each client with initial notice of the firm’s current policy when the client relationship is established. Alpha shall also provide each client with a new notice of the firm’s current privacy policies at least annually. If, at any time, Alpha adopts material changes to its privacy policies then the firm shall provide each client with a revised notice reflecting the new privacy policies.
Notice to California Clients Required by State Law
California residents, please click here.
Should you have any questions regarding the above, please contact:
Alpha RIA LLC, Attention: Chief Compliance Officer
40 Wall Street, 28th Floor
New York, NY 10005
Direct: +1 (212) 933-9340