Tandem Capital Management, Inc.
Preserving client confidentiality is a high priority at Tandem Capital Management, Inc. (“Tandem Capital”). We do not sell or rent client information to anyone. Nor do we share such information with any affiliated or non-affiliated third parties beyond those directly necessary to render Tandem Capital’s investment management services for the benefit of our clients. We require all of our employees to safeguard personal information about our clients, prospective clients and former clients. In light of the Securities and Exchange Commission Regulation S-P regarding privacy requirements for investment advisors, the sections that follow explain in more detail what client information we collect, who has access to this information and how we protect it.
This policy applies to past and present clients.
Information We Collect about You
Tandem Capital Management, as an investment advisor, collects information about you to help us serve your financial and investment needs, provide you with quality service, and fulfill legal and regulatory requirements. We consider all information about you in our possession to be personal information, whether you are a current or former client. The information we collect comes from applications and other forms you submit, conversations you may have with our financial professionals and staff, and your correspondence with our firm. This personal information may include, among other things, the following:
- Identifying information, such as your name, age, address, telephone number and social security number.
- Financial information, including your income, assets and liabilities, as well as information about your savings, investments, insurance and business.
- Information regarding your immediate family and dependents.
- Information about your financial and investment objectives, needs and preferences.
- Information about your investment experience and attitudes towards investment risk.
- Information from transactional activity in your account.
- Information from wire transfer instructions.
- Our policy is to permit the financial professionals and administrators of Tandem Capital Management access to your personal information only if they have a business purpose for using such information. We define “business purpose” to include the opening or closing of an account, administering an account, servicing the account pursuant to instructions or inquiries from the client or investment manager, or otherwise in furtherance of our business.
- We do not sell or rent your personal information to anyone.
- As an investment manager, Tandem Capital Management will share necessary personal information as part of the account-servicing function. In addition to the custodian/broker-dealer that you have selected for your securities account and through which we manage your investment assets, our software-application providers may temporarily house downloaded custodian data on their secure servers for conversion to their application.
- When instructed by you as the owner or trustee of an account, we will share information with other parties that you authorize. (For example, we will follow your instructions to forward account activity information to your accountant, pension administrator, attorney, etc.)
- We share personal information about you where required by law or regulation, as when responding to a subpoena, court order, judicial process or government regulatory authority.
- Except as noted in items 3, 4, and 5 above, we do not disclose your personal information to any non-affiliated third parties without your consent unless permitted by law.
Protecting Client Information
Tandem Capital’s Compliance/Ethics Policy governs the conduct of all our employees and requires all employees to safeguard client personal information, including the identities of our clients.
We maintain physical, electronic, and procedural safeguards to protect your information.