Privacy PolicyGreat Point Capital & Great Point Advisors, LLC

Privacy Policy

Privacy Policy

At Great Point Capital (“GPC”), protecting your privacy is very important to us. We value your trust and want you to understand what information we collect, how we use it, and how we protect it. The Gramm-Leach-Bliley Act, passed in 1999, requires that all companies distributing financial and insurance products to the public develop and publish a privacy policy. GPC’s Privacy Policy provides information relating to how and when we share customer information with unaffiliated third parties. A copy of our privacy policy is delivered to clients at the time of account opening – either hand-delivered or by mail, and annually thereafter – by mail, to the last known address.

Personal Information We May Collect

During our relationship, GPC may obtain nonpublic personal information from you. The information we obtain assists the firm and our Financial Advisors in providing you with products and services, and also to satisfy regulatory requirements. This information may be obtained from various sources including:

• Account applications and other forms,
• Your transactions with us or others,
• From written, electronic and verbal correspondence and communication, and/or
• From a consumer reporting agency.

The Balance of Respecting Your Privacy &
Sharing Information with Third Parties

As a matter of policy, GPC does not disclose personal or account information provided by clients to non-affiliated third parties, except as follows:

• When required or permitted by law, or as necessary for third parties to perform their agreements with respect to services performed on our behalf.
• To administer, manage, service, and provide related services for client accounts, it is necessary for Great Point to provide access to client information within the firm and to non-affiliated companies, with whom we have entered into agreements. The disclosure of information contained in any document completed by the client for processing and/or transmittal by Great Point to facilitate the commencement, continuation, and/or termination of a business relationship between the client and/or between Great Point and a non-affiliated third-party service provider (i.e., broker-dealer, investment adviser, account custodian, recordkeeper, insurance company, etc.), including, but not limited to, the information contained in any document completed and/or executed by the client in furtherance of the client’s engagement of Great Point (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding non-affiliated third-party service provider.

GPC reserves the right to:

• In limited circumstances, disclose or report personal information to non-affiliated third parties when the firm believes in good faith that disclosure is required under law, and to cooperate with regulators or law enforcement authorities as may be requested.
• Disclose information about client accounts to a non-affiliated third party at the client’s request, or with the consent of the client.
• Disclose personal information that is necessary in providing administrative, custodial, or customer assistance, and in preparing, printing and delivering statements and other client related documents. These companies include clearing firms, mutual fund, annuity and other financial services companies that aid in fulfilling these services to our clients.
• GPC does not provide information about our clients or former clients to any non-affiliated third party for marketing purposes.

Opt Out Provision

If your Financial Advisor leaves GPC to join another broker-dealer that is a member of the Protocol for Broker Recruiting (to which our firm is a signatory), we may permit your advisor to retain certain contact information that may be used by his/her new firm; limited to your name, address, email address, phone number, account title, and account type. If you object to such information being retained by your Financial Advisor or shared with his/her new firm, you may opt-out by contacting our Compliance Department at 312-517-2606 or emailing [email protected].

Procedures to Safeguard Private Information

GPC maintains procedures and technology designed to prevent unauthorized access to private personal information. We restrict access to personal information to employees and service providers who need to know that information to provide products or services to you. Employees who violate our Privacy Policy are subject to company and regulatory disciplinary action.

When accessing your account via a link from www.GreatPointCapital.com using a browser, such as Netscape Navigator or Microsoft Internet Explorer, it is encrypted using Secure Socket Layer (SSL) 128-bit encrypted security. This technology is used to protect the confidentiality of your personal information.

Change in Privacy Policy

GPC reserves the right to modify or supplement this Privacy Policy at any time. If a material change is made, we will provide current clients with a revised notice that describes our new policy and if such practices so require, we will give them a reasonable opportunity to opt-out of the disclosure of information under the revised Privacy Policy.

Customer Identification Program

Customer Identification Program

To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify, and record information that identifies each person who opens an account.

This Notice answers some questions about this broker/dealer’s Customer Identification Program.

What types of information are required to be provided?

At the time you open an account with us, we are required to collect information such as the following from you:

• Your name
• Your date of birth
• Your address
• An identification number
  • U.S. Citizen: taxpayer identification number (social security number or employer identification card)
  • Non-U.S. Citizen: taxpayer identification number, passport number, and country of issuance, alien identification number or you may also need to show your driver’s license or other identifying documents.

A corporation, partnership, trust, or other legal entity may need to provide other information such as its principal place of business, local office, employee identification number, certified articles of incorporation, government-issued business license, a partnership agreement, or a trust agreement.

U.S. Department of the Treasury, Securities and Exchange Commission, FINRA, and New York Stock Exchange rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience and objectives, and risk tolerance.

What happens if I don’t provide the information requested, or my identity cannot be verified?

GPC may not be able to open an account or carry out transactions for you. If we have already opened an account for you, we may have to close it.

We thank you for your patience and cooperation and hope that you will support the financial services industry’s efforts to deny terrorists and money launders access to America’s Financial System.