Privacy Policy

Winter Harbor Advisors, L.L.C., maintains a privacy policy to protect non-public personal information provided to the Advisor by clients and prospective clients, as summarized below. In addition to providing a written copy of the privacy policy to each client upon establishment of a client relationship and at least annually thereafter, Winter Harbor Advisors will provide a written copy of the privacy policy upon request.

Winter Harbor Advisors, L.L.C., is committed to protecting the confidentiality of any non-public personal information we collect concerning our clients and prospective clients in order to perform our investment management and financial advisory activities. Accordingly, we maintain a privacy policy and various procedures which are designed to safeguard your non-public personal information and limit access to and use of such information only for appropriate and authorized purposes.

In addition to the non-public personal information you specifically disclose to us (through telephonic or electronic communications with us or through the submission of contracts, agreements, or other documents to us), we may also collect certain non-public personal information about you through other means, such as through the execution of transactions within your account(s).

We maintain physical, electronic, and procedural safeguards to protect your non-public personal information. We restrict access to your non-public personal information to our employees and the employees of third party organizations who provide services necessary to manage your account(s).

Where information is released by us to employees of third party organizations, we attempt to ensure that these organizations have similar or reasonable privacy policies to further protect your non-public personal information.

We will not disclose your non-public personal information to any unaffiliated third party unless permitted or require by law. This obligation continues even if you decide to end any client relationship with us.