Privacy Policy

Your Privacy Is Important To Us

In the course of serving you as an individual client, Stickney Research may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

This Policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information, and the steps that we take to protect your privacy.

The Sources of Information We Collect

The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to Stickney Research during the course of your relationship with us. We may also collect information about your transactions and experiences with Stickney Research relating to the products and services Stickney Research provides.

The Information We Have About You

If you engage with Stickney Research in your individual capacity (e.g., as a private client), the typical information we collect about you may include all or some of the following:

  • Your name, address and other contact details
  • Your age, occupation and marital status
  • Financial information, including source of wealth, investment experience and objectives, risk tolerance and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources
  • A head and shoulders photograph from, as applicable, your passport, national identity card or driver’s license, as required by laws and regulations addressing due diligence and related matters; and
  • A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc.

You are not required to supply any of the personal information that we may request; however, some personal information is required in order for us to act on your behalf.

Our Use of Your Personal Information

We may use your personal information to:

  • Administer, operate, facilitate and manage your relationship and/or account with Stickney Research. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively
  • Contact you or (if applicable) your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account
  • Provide you with information (such as investment research), recommendations or advice concerning products and services offered by Stickney Research; and
  • Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements
  • If your relationship with Stickney Research ends, Stickney Research will continue to treat your personal information, to the extent we retain it, as described in this Policy.

Disclosures of Your Personal Information Within Stickney Research

In order to provide efficient and reliable services, and to improve product and service options available to you, more than one entity within Stickney Research may be given, or given access to, your personal information. When so sharing your personal information we adhere to applicable legal and industry standards regarding the protection of personal information.

Disclosures of Your Personal Information to Third Parties

Stickney Research does not disclose your personal information to third parties, except as described by this Policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with Stickney Research, including those that provide professional, legal, or accounting advice to Stickney Research. Non-affiliated companies that assist Stickney Research in providing services to you are required to maintain the confidentiality of such information to the extent they receive it, and to use your personal information only in the course of providing such services and only for the purposes that Stickney Research dictates.

We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners, or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations, for instance, when responding to a subpoena or similar legal process, to protect against fraud, and to otherwise cooperate with law enforcement or regulatory authorities, or with organizations such as exchanges and clearinghouses.

Stickney Research will not sell your personal information. Other Privacy Policies or Statements; Changes to Policy

This Policy provides a general statement of the ways in which Stickney Research protects your personal information. You may, however, in connection with specific products or services offered by Stickney Research, be provided with privacy policies or statements that supplement this Policy. This Policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised Policy will be effective immediately upon posting to our Web site. This version of the Policy is effective October 1st, 2020.