Last revision April 21, 2001
This Privacy Notice describes Union Gaming Research, LLC (the “Company”) privacy policies and procedures with respect to nonpublic personal information of the Company’s clients, prospective clients and former clients. These policies serve as a standard for all Union Gaming Research, LLC employees for the collection, use, retention and security of nonpublic personal information. These policies may be updated as required to provide additional safeguards and ensure that the Company complies with any federal or state regulatory agencies compliance requirements.
The Company collects and maintains nonpublic personal information about clients as follows:
- Information we receive in investment management agreements, client profile questionnaires, and other forms which clients may complete and submit to us, such as names, addresses, phone numbers, social security numbers, and employment, income and other household information;
- Information we receive and maintain relating to clients’ assets, such as brokerage statements;
- Information about your investments and transactions with us and our affiliates, including information we receive and maintain relating to hot issue and other securities transactions with and through accounts we manage; and
- Information we receive about a client from the client’s financial advisor, investment consultant or other financial institution with whom the client has a relationship and /or whom the client may have authorized to provide such information to the Company.
The Company does not disclose any nonpublic personal information about its clients, prospective clients or former clients except as may be required or permitted by law. The Company may disclose information about a client to its affiliates, and to the following types of third parties:
- Financial service providers such as the Company’s prime broker who assist the Company as part of the ordinary course of servicing your accounts that are managed by the Company;
- Representatives of the Company, such as our counsel, accountants and auditors;
- Persons or organizations acting in a fiduciary or representative capacity on behalf of a client, such as a custodial firm or a transfer agent.
On all occasions when it is necessary for the Company to share your personal information with non-affiliated companies, the Company will require that such information only be used for the limited purpose for which it is shared and will advise these companies not to further share your information with others except to fulfill that limited purpose.
The Company takes its responsibility to protect the privacy and confidentiality of client information very seriously. We restrict access to nonpublic information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards to guard your nonpublic personal information. We provide clients with a Privacy Notice as part of the investment management materials and annually after that. If the Company changes its privacy policies to permit it or its affiliates to share additional information the Company has about you, or to permit disclosures to additional types of parties, you will be notified in advance, and, if required by law, you will be given the opportunity to opt out of such additional disclosure and to direct us not to share your information with such parties.
If you have any questions or concerns about this Privacy Notice, please contact us at:
Union Gaming Research, LLC
Attn: Richard P. Moriarty
Chief Compliance Officer
3930 Howard Hughes Parkway
Las Vegas, NV 89169