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Privacy Policy

GAVEKAL is made up of several groups and this policy applies to all companies within the group (which will hereby be referred to as “GAVEKAL”.) GAVEKAL requires that you provide current and accurate personal information and some groups may require financial information in compliance with the law. This policy applies to all users and customers or anyone that is ordering, registering or interacting with any product or service from GAVEKAL or its affiliates including but not limited to attendees, subscribers, registrants, website users, etc.

GAVEKAL is committed to protecting your privacy and the information you provide in a manner that is safe, secure and professional. GAVEKAL and its employees are committed to safeguarding that information.

Safeguarding Information

GAVEKAL collects non-public customer data in checklists, forms, in written notations, and in documentation provided to us by our customers for evaluation, registration, licensing or related consulting services. We also create internal lists of such data.

Customer’s information collected by GAVEKAL will be kept so long as their account remains active. If an account becomes inactive, information may be kept for at least six years or for such period of time as may be required by legal and regulatory requirements.

Customers have the right to access, amend and rectify their personal data, to lodge a complaint with a supervising authority, the right to be forgotten, to restrict processing and to object to processing whereby personal data is being processed for direct marketing purposes. If a customer wishes to amend their consent, they can email their request to the Data Protection Officer at dpo@gavekal.com at any time. The DPO will respond to your written request to exercise these rights as soon as is practicable and within one month of receipt of your request. GAVEKAL does not sell personal data to third parties.

During regular business hours access to customer records is monitored so that only those with approval may access the files. During hours in which the company is not in operation, customer records are locked.

No individual who is not so authorized shall obtain or seek to obtain personal and financial customer information. No individual with authorization to access personal and financial customer information shall share that information in any manner without the specific consent of a firm principal. Failure to observe GAVEKAL's procedures regarding customer and consumer privacy will result in discipline and may lead to termination.

We take information security seriously and have policies and procedures in place to make sure your information remains safe. If GAVEKAL suffers a personal data breach, affected customers will be notified of the breach as soon as is practical.

Sharing Nonpublic Personal and Financial Information

GAVEKAL is committed to the protection and privacy of its customers' and consumers' personal and financial information. GAVEKAL will not share such information with non-affiliated third parties except:

  • When necessary to complete a transaction in a customer account, such as with the clearing firm or account custodians;
  • When required to maintain or service a customer account;
  • To resolve customer disputes or inquiries;
  • With persons acting in a fiduciary or representative capacity on behalf of the customer;
  • With rating agencies, persons assessing compliance with industry standards, or to the attorneys, accountants and auditors of the firm;
  • In connection with a sale or merger of GAVEKAL's business;
  • To protect against or prevent actual or potential fraud, identity theft, unauthorized transactions, claims or other liability;
  • To comply with federal, state or local laws, rules and other applicable legal requirements;
  • In connection with a written agreement to provide investment management or advisory services when the information is released for the sole purpose of providing the products or services covered by the agreement; or
  • In any circumstances with the customer's instruction or consent.

Opt-Out Provisions

It is not a policy of GAVEKAL to share nonpublic personal and financial information with unaffiliated third parties except, but not limited to, the circumstances noted above. Since sharing may be necessary to service customer accounts or is mandated by law, there are no allowances made for clients to opt out.