Privacy Policy

BakerAvenue Privacy Policy Statement

- California Consumer Privacy Act (CCPA)

Privacy Policy

BakerAvenue has adopted this privacy policy with recognition that protecting the privacy and security of the personal information we obtain about our customers is an important responsibility. We also know that you expect us to service you in an accurate and efficient manner. To do so, we must collect and maintain certain personal information about you. We want you to know what information we collect and how we use and safeguard that information.

Information We Collect: We collect certain nonpublic information about you (“Customer Information”). The essential purpose for collecting Customer Information is to allow us to provide advisory services to you. Customer Information we collect may include:

• Information that you or your affiliates provide to BakerAvenue, on applications or other forms. This Customer Information may include personal and household information such as income, spending habits, investment objectives, financial goals, statements of account, and other records concerning your financial condition and assets, together with information concerning employee benefits and retirement plan interests, wills, trusts, mortgages and tax returns.
• Identifying information such as your name, age, address, social security number, etc.
• Information about your transactions with us, or others (e.g., broker-dealers, clearing firms, or other chosen investment sponsors).

Information we receive from consumer reporting agencies (e.g., credit bureaus), as well as other various materials we may use to provide an appropriate recommendation or to fill a service request.

Security of Your Information: We restrict access to your nonpublic personal information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your nonpublic personal information.

Information We Disclose: We do not disclose the nonpublic personal information we collect about our customers to anyone except: (i) in furtherance of our business relationship with our customers and then only to those BakerAvenue employees, affiliates and third-party service providers necessary to effect the transactions and provide the authorized services (such as broker-dealers, custodians, independent managers, software providers, etc.); (ii) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, consultants, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided by law. We are permitted by law to disclose the nonpublic personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf or for joint marketing programs). These third parties are prohibited to use or share the information for any other purpose.

Former Clients: If you decide to close your account(s) or become an inactive customer, we will adhere to our privacy policies, which may be amended from time to time but will not share or disclose any of customer’s nonpublic personal information with third parties except as otherwise expressly provided under the provisions of Section 3.

Changes to Our Privacy Policy: In the event there were to be a material change to our privacy policy regarding how we use your confidential information, we will provide written notice to you. Where applicable, you would be given an opportunity to limit or opt-out of such disclosure arrangements.

Questions: If you have questions about this privacy notice or about the privacy of your customer information call our main number 415-986-1110 and ask to speak to the Chief Compliance Officer.

California Consumer Privacy Act (CCPA)

Notice for California Consumers:

The California Consumer Privacy Act of 2018 (“CCPA”) becomes effective on January 1, 2020 and creates a variety of privacy rights for California consumers. We share the same information about our practices with everyone but use this notice to make disclosures required by the CCPA.

This notice includes the following parts and make this information available to you in our Privacy Policy above.

• Transparency: We are transparent about how your personal information is collected, used, shared and sold.
• Control: We put you in control of your personal information, including accessing and deleting your personal information.
• Benefits to You: We use your personal information to benefit you and to make your experiences better.

You have the right to know:

• what kinds of personal information Baker Avenue Asset Management, LP is collecting and our business purposes for that collection.
• how personal information is obtained, how it is used, and our business purposes for that use.
• if your personal information is shared with any third parties. We may share personal information to have Service Providers, as defined by the CCPA, perform services specified by written contract.

In addition, we may share personal information with third parties for other notified purposes, as permitted by the CCPA.

We Do Not Sell Your Personal Information

You have the right to:

• Know what specific pieces of personal information Baker Avenue Asset Management, LP has collected and retained about you over the previous 12 months.
• Receive a copy of your personal information.
• Delete your personal information.

For more detailed inquiries, you can submit a request to bakeravenue@bakerave.com

Non-Discrimination

The CCPA prohibits businesses from discriminating against you for exercising your rights under the law. Such discrimination may include denying a good or service, providing a different level or quality of service, or charging different prices. The CCPA permits businesses to provide differing levels or quality or different prices where the business can demonstrate that the difference is reasonably related to the value to the business of the consumer’s personal information.

¹ Nonpublic personal information means personally identifiable financial information and any list, description or other grouping of consumers that is derived using any personally identifiable financial information that is not publicly available.