Privacy Policy

KL Winterbourne Associates understands its obligation to protect and preserve the privacy of our clients. We are engaged in the business of providing investment management advice to individual investors. Owing to the nature of our business, we need to ask for, acquire and hold information about our clients that may be considered personally identifying. With this in mind, we have prepared this privacy policy to outline clearly, how we process, use, store and share information that we hold about our clients in the course of carrying out our business.

The information we collect

In order to provide you with a standard of service commensurate with your goals, we need to obtain certain information about your personal and financial circumstances and may gather the following information:

  • Your name, age, date of birth and, where applicable, Social Security identification numbers
  • Your contact details both personal and professional: these could include your physical address, your email address and your telephone number
  • Personal financial information:
    • details of your employment
    • details about your net worth including your income, the value of any existing investments, the value of any individual retirement accounts, information regarding real estate ownership and your bank details.
  • Information regarding your attitude to investment risk
  • Information about the level of your investment market sophistication
  • Internal Protocol (IP) address: we collect this information passively when you visit our website

We use only lawful means to gather information and, ordinarily, will not have access to information from third parties other than those you authorize to disseminate such information to us.

These third parties may include:

  • Attorneys
  • Accountants
  • Trustees of a trust you are connected with

How and why we use this information

We publish this policy in order to ensure that you understand what KL Winterbourne Associates do and why. It also serves to ensure that, in the event that you should wish to challenge us, you have the information you need about your rights. Because so much about the way we handle data is dependent upon your personal needs and circumstances, it is not practical to provide extensive detail about the manner in which we process personal data.

Disclosure of information

KL Winterbourne Associates takes your privacy very seriously. In the normal course of conducting our business, we will not disclose or share any personally identifying information with any third party without your full, written authorization. There are however, certain circumstances under which we will need to share personally identifying information about you with third parties.

An instance like this would occur if we needed to allocate some of your capital to a mutual fund provided by a third party. Also, we may need to disclose personally identifying information about you if we are compelled to by a legal court order.

Safeguarding your privacy

KL Winterbourne Associates allocates significant resources to technological infrastructure designed to protect electronically-held information. Information held about you is stored on secure servers protected by hardware and software firewalls as well as with third-party cloud storage providers on encrypted servers.

Policy changes

KL Winterbourne Associates reserves the right to make amendments to this policy without the provision of notice. In the event that we decide to make an amendment to this policy, we will post the updated policy on our website ensuring that you are always aware of the personal information we gather, how we use it and under what circumstances we will disclose it.