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Pinnacle Alternative Investments LLC protects the confidentiality
of our client's personal financial information as required
by law, accreditation standards and our internal policies
and procedures. This client PRIVACY POLICY statement explains
your rights, our legal duties and our privacy policy practices.
Under Section 503 of the Gramm-Leach-Bliley Act ("Act"),
a financial institution must provide its customers with a
notice of its privacy policies and practices, and must not
disclose nonpublic personal information about a consumer to
nonaffiliated third parties unless the institution provides
certain information to the consumer and the consumer has not
elected to opt out of the disclosure. Part 160 of the rules
of the Act requires the implementation of said Act with respect
to futures commission merchants, commodity trading advisors,
introducing brokers and commodity pool operators.
Since Pinnacle Alternative Investments LLC ("Pinnacle")
does not intend on sharing non-public personal information
with non-affiliated third parties, a "simplified notice"
to our clients is the requirement, which we intend to conform
with, and in so doing, are required to make known to our clients
3 essential features of the provision.
The first is that which deals with 3 categories of nonpublic
personal information that are collected. Since the vast majority
of information acquired by Pinnacle and its clearing affiliate
is financial in nature, this information (first category)
is provided through the account opening process when the client
completes the requisite documentation necessary to open a
brokerage account and as such, is kept on file at the offices
of Pinnacle and its clearing affiliate. This information is
not shared with any other party except the clearing affiliate.
The second category includes any information about a client
resulting from any transaction between the client (consumer)
and the financial institution involving a financial product
or service. Again, Pinnacle maintains a policy of not disclosing
such information (unless prior approval is first granted by
the client). The third category of information is any financial
information about a consumer (client) otherwise obtained by
the financial institution in connection with providing a financial
product or service. This would include information obtained
indirectly through the internet ("cookie") or information
from a consumer report or outside source. Once again, Pinnacle
does not intend to and maintains a policy of not distributing
such information to any unrelated third-party.
In meeting the second feature of the provision Pinnacle is
required to state what its policy is for protecting the security
and confidentiality of the information acquired. Pinnacle
files and maintains all client records at its offices in a
secure environment with limited access to said
information. Only principals of Pinnacle (and duly authorized
employees) are allowed access the client files (nonpublic
personal information). Furthermore, all electronically stored
client information is protected by network secured "firewall"
technology.
The third feature of the provision requires that Pinnacle
(if it intends to share nonpublic personal information with
unaffiliated third parties) make the statement to its clients
that it intends to do so. Pinnacle maintains a policy of not
disseminating such information to said parties and would only
do so with prior written approval of the client.
Other related provisions of the Act that the client may wish
to become familiar with include Sections 160.14 and 160.15,
which detail "exceptions to the notification requirements"
and various "opt out" requirements. The information
included under these headings is beyond the scope and mandate
of this notice.
If, as a client of Pinnacle Alternative Investments LLC,
you desire to become more familiar with the full provisions
and details of 160 of the Gramm-Leach-Bliley Act, you may
request in writing that a copy of said Act be delivered to
your address provided for on the client account form. One
will be mailed (or e-mailed, if you prefer) to you promptly.
If you have any questions regarding any of the related provisions
of the Act you can call Pinnacle Alternative Investments LLC
at #713-520-5984 or put your questions in writing and forward
these questions to the following address:
Pinnacle Alternative Investments LLC
Attention: Compliance Department
3700 Wakeforest Dr., Suite 34
Houston, TX. 77098
Pinnacle Alternative Investments LLC would once again like
to assure its clients that it intends to maintain a policy
of not disclosing nonpublic personal information to any unaffiliated
third parties. In the event that we feel it appropriate to
do so, such actions will not be taken without prior written
approval from the client. Your privacy and confidentiality
is of paramount importance to us and we intend maintain a
policy that reflects this philosophy.
Respectfully,
Jacques P. DeRouen
Managing Director
Pinnacle Alternative Investments LLC
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