Colva Capital (and its affiliated investment advisers and funds), considers your privacy our utmost concern. Because safeguarding your personal information is important to us, we will not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law and described below.
We restrict access to nonpublic personal information about you to those employees who need to know that information to provide our services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information. We do not sell personal information to parties not affiliated with us for the purpose of marketing their services or products to you or for any other purpose, and we do not share your personal information with other parties except in the limited circumstance discussed below.
Our Gathering of Information About You
We collect the following types of nonpublic personal information about you:
- Information you supply on applications or other forms, such as your name, address, social security number, assets, and income and similar information. We use this information in providing our investment advisory services to you or in managing your employment application.
- Information about your transactions with us or others, such as your account balance and account transactions. We use this information to evaluate your financial situation and provide better services to you.
Our Sharing of Information About You with Others
As permitted by law, we may disclose some or all of the information we collect, as described under “Our Gathering of Information About You,” to nonaffiliated third parties to service your account and to provide services you request. Such nonaffiliated third parties include:
- Companies that provide financial services, such as broker-dealers, banks, mutual fund companies and insurance companies.
- Non-financial companies, such as companies that assist us in marketing our services.
- Others who provide services to us, such as parties who provide technical support for our hardware and software systems and our legal and accounting professionals, as well as government agencies and other parties as permitted or required by applicable law.
The information we share with parties that provide us with marketing and other services is limited to information they need to perform their services and we require such parties to agree to use the information only for the purpose of performing their services.
What are cookies?
Cookies are small text files that are stored in your computer’s memory and hard drive, in your mobile device or tablet when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website, or other third parties that receive data obtained from that website.
When you visit any website, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience.
- Analytical purposes: Analytical cookies allow us to recognize, measure and track visitors to our Websites and compile a record of this usage information. This helps us to improve and develop the way our Websites work, for example, by determining whether site visitors can find information easily, or by identifying the aspects of websites that are of the most interest to them.
- Usage preferences: Some of the cookies on our Websites are activated when visitors to our sites make a choice about their usage of the site. Our Websites then ‘remember’ the settings preferences of the user concerned. This allows us to tailor aspects of our sites to the individual user.
- Functional purposes: Functional purpose cookies store information that is needed by our applications to process and operate. For example, where transactions or requests within an application involve multiple workflow stages, cookies are used to store the information from each stage temporarily, in order to facilitate completion of the overall transaction or request.
Your cookie preferences
Cookies are necessary in order for you to be able to make full use of Tortoises’ Websites. In addition, cookies help us provide you with personalized features on our Websites. If you chose to disable cookies, some of our Websites’ functionality might be impaired.
The site www.allaboutcookies.org includes instructions for managing cookies on many commonly used browsers, or you may consult the vendor documentation for your specific software.
Further information about cookies
If you would like to find out more about cookies in general and how to manage them, please visit www.allaboutcookies.org.
Our Continued Protection of the Privacy of Former Clients
You may contact us in order to exercise any of your rights set forth in this privacy notice by calling us toll-free at +1 646 762 2800 or emailing us at [email protected].
Certain Additional Information for California Residents:
If you are a California resident, you have the right to request that we disclose to you, free of charge, the categories and specifics of the personal information we collect about you (and if, applicable, otherwise disclose about you to a third party for business purposes). We require a verifiable request from you to ensure that it is, in fact, you who is requesting this information. Once we verify the request, we will provide that information to you.
Your request for disclosure can apply to any such personal information mentioned above for as much as twelve months preceding your request. Be advised that we are not required to disclose such information about the personal information we collect about you more than twice in a twelve-month period.
Following our verification of your request, we will disclose to you, unless otherwise restricted by law or regulation the following personal information we collect about you:
- The categories of personal information we have collected about you
- The categories of sources from which the personal information is being collected
- The business or commercial purpose for collecting that personal information
- The categories of third parties with whom we share personal information
- The specific pieces of personal information we have collected about you
We will also disclose to you, unless otherwise restricted by law or regulation, the following personal information about you that we disclose for business purposes:
- The categories of personal information we have collected about you that we disclose to third parties
- The categories of sources from which that personal information is collected
- The business or commercial purpose for collecting and/or disclosing that personal information
You have the right to request that we delete the personal information that we have collected from you. Following our verification of your request, we will comply with your request and delete any or all of your personal information in our possession that we collected from you and/or any or all such personal information in the possession of our service providers, unless otherwise restricted by law or regulation.