In November of 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA). The GLBA requires certain financial institutions, such as investment advisor firms, to protect the privacy of client information. In situations where a financial institution does disclose client information to non-affiliated third parties, other than permitted or required by law, client must be given the opportunity to opt out or prevent such disclosure. Grove does not share or disclosure client information to non-affiliated third parties except as permitted or required by law.
Grove is committed to safeguarding the confidential information of its clients. Grove holds all personal information provided by clients in the strictest confidence and it is the objective of Grove to protect the privacy of all clients. Except as permitted or required by law. Grove does not share confidential information about clients with non-affiliated parties. In the event that there were to be a change in this policy, Grove will provide clients with written notice and clients will be provided an opportunity to direct Grove as to whether such disclosure is permissible.
To conduct regular business, Grove may collect personal information from sources such as:
• Information reported by the client on applications or other forms the client provides to Grove.
• Information about the client’s transactions implemented by Grove or others.
• Information developed as part of financial plans, analyses, or investment advisory services.
To administer, manage, services, and provide related services for client accounts, it is necessary for Grove to provide access to client information within the firm and non-affiliated companies with whom Grove has entered into agreements with. To provide the utmost service, Grove may disclose the information below regarding clients and former clients as necessary to companies to perform certain services on Grove’s behalf.
• Information Grove receives from the client (name, social security number, address, assets, etc.)
• Information about the client’s transaction with Grove or others (account information, payment history, etc.)
• Information concerning investment advisory account transactions.
• Information about a client’s financial products and services transactions with Grove
Since Grove shares nonpublic information solely to service client accounts, Grove does not disclose any nonpublic personal information about Grove’s clients or former clients to anyone, except as permitted by law. However, Grove may also provide client information outside of the firm as required by the law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas, In the event that Grove has a change to its client privacy policy that would allow it to disclose non-public information not covered under applicable law, Grove will allow its clients the opportunity to opt out of such disclosure.