Privacy Notice

 At D2 Capital Management, LLC, your privacy is very important to us. We collect, use and share personal information about you in order to open your account(s), to process your transactions and to help us provide a better level of service. Details of our approach to privacy and how your personal information is collected and used are set forth in this Notice of Privacy Policy. The practices described in this policy are applicable to all customers, including current and former customers. We do not sell your personal information to anyone. We protect the security and confidentiality of the personal information we collect.

Our relationship with you is very important to us. You have entrusted us with your personal and financial information, and we will do everything we can to keep your trust and confidence.

  • We do not sell your personal information.
  • We do not disclose personal information to third parties, unless one of the following limited exceptions applies:
    • We disclose personal information to companies that perform services on our behalf, help us in responding to inquiries, process or service your transactions or account(s), including companies that print and mail your account statements or other forms of shareholder servicing providing they use the information solely for those purposes.
    • We may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required or permitted under law, for example, to cooperate with regulators or law enforcement authorities, resolve consumer disputes, perform credit/authentication checks, or for institutional risk control.

Outside of these exceptions, we will not share your personal information with third parties unless you have specifically asked us to do so.

  • We collect personal information in the normal course of business in order to identify you, evaluate your application, service and manage your account, offer services and products and administer your accounts so that we can serve you better. We collect this information from a variety of sources including:
    • We collect information that you provide to us when you open an account and complete an application or other forms. The information we collect may include name, address, phone number, email address, social security number, and information about your interests, investments, and investment experience. We also may collect information from consumer reporting agencies;
    • Once you have an account with us, to administer your account and provide the best service possible to you, we collect and maintain personal information about your transactions, including balances, positions, and history, and may include your name or other data in our internal system that reflect your activities.
  • We protect the confidentiality and security of your personal information.
    • Third party providers that we hire to provide support services are not permitted to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to the performance of the specific service we have requested.
    • Only authorized personnel who are trained in the proper handling of customer information to have access to your personal information.
    • We maintain physical, electronic, and procedural safeguards to guard your personal information.
    • We will not reveal customer information to any external organization unless we have previously informed the customer in disclosures or agreements, have been authorized by the customer or are required by law or our regulators.
  • We continue to evaluate our efforts to protect personal information and make every effort to keep your personal information accurate and up to date. Therefore, if you notice any inaccuracy in your personal information, or your information changes, please contact us so that we can make these changes to our records.
  • We will provide notice of changes in our privacy policy practices. If it becomes necessary to disclose any of your personal information in a way that is inconsistent with this policy, we will give you advance notice of the proposed change so that you will have the opportunity to opt out of such disclosure.

These Privacy Policies apply to individuals, and we reserve the right to change these Privacy Policies, and any of the policies or procedures described above, at any time. Under such circumstances, we will provide you with an updated set of our policies, and will provide adequate time for you to opt out of any information sharing arrangement. These Privacy Policies are for general guidance and do not constitute a contract or create legal rights and do not modify or amend any agreements we have with our clients.