Privacy Policy
Privacy Notice Regarding Client Privacy as Required by Regulation S-P & Regulation S-AM
Maintaining the trust and confidence of our clients is a high priority. That is why we want you to understand how we protect your privacy when we collect and use information about you, and the steps that we take to safeguard that information. This notice is provided to you on behalf of Gilbert & Cook, Inc.
Information We Collect: In connection with providing investment products, financial advice, or other services, we obtain non-public personal information about you, including:
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Information we receive from you on account applications, such as your address, date of birth, Social Security Number, occupation, financial goals, assets and income;
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Information about your transactions with us, our affiliates, or others; and
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Information received from credit or service bureaus or other third parties, such as your credit history or employment status.
Categories of Parties to Whom We Disclose: We will not disclose information regarding you or your account at Gilbert & Cook, Inc., except under the following circumstances:
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To entities that perform services for us or function on our behalf, including financial service providers, such as a clearing broker-dealer, investment company, or insurance company, other advisers;
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To consumer reporting agencies,
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To third parties who perform services or marketing, client resource management or other parties to help manage your account on our behalf;
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To your attorney, trustee or anyone else who represents you in a fiduciary capacity;
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To our attorneys, accountants or auditors; and
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To government entities or other third parties in response to subpoenas or other legal process as required by law or to comply with regulatory inquiries.
How We Use Information: Information may be used among companies that perform support services for us, such as data processors, client relationship management technology, technical systems consultants and programmers, or companies that help us market products and services to you for a number of purposes, such as:
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To protect your accounts/non-public information from unauthorized access or identity theft;
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To process your requests such as securities purchases and sales;
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To establish or maintain an account with an unaffiliated third party, such as a clearing broker-dealer providing services to you and/or Gilbert & Cook, Inc.;
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To service your accounts, such as by issuing checks and account statements;
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To comply with Federal, State, and Self-Regulatory Organization requirements;
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To keep you informed about financial services of interest to you.
Regulation S-AM: Under Regulation S-AM, a registered investment adviser is prohibited from using eligibility information that it receives from an affiliate to make a marketing solicitation unless:
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the potential marketing use of that information has been clearly, conspicuously and concisely disclosed to the consumer;
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the consumer has been provided a reasonable opportunity and a simple method to opt out of receiving the marketing solicitations; and
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(3) the consumer has not opted out. Gilbert & Cook, Inc. does not receive information regarding marketing eligibility from affiliates to make solicitations.
Regulation S-ID: Regulation S-ID requires our firm to have an Identity Theft Protection Program (ITPP) that controls reasonably foreseeable risks to customers or to the safety and soundness of our firm from identity theft. We have developed an ITPP to adequately identify and detect potential red- flags to prevent and mitigate identity theft.
Our Security Policy: We restrict access to nonpublic personal information about you to those individuals who need to know that information to provide products or services to you and perform their respective duties. We maintain physical, electronic, and procedural security measures to safeguard confidential client information.
Closed or Inactive Accounts: If you decide to close your account(s) or become an inactive customer, our Privacy Policy will continue to apply to you.
What You Can Do: For your protection, we recommend that you keep your account information and log in credentials confidential. If you become aware of any suspicious activity related to your accounts, please contact us immediately in accordance with the “Contacting Us” section below.
How You Can Access, Change or Suppress Your Personal Data: If you would like to review, correct, update, suppress, restrict or delete Personal Data that you have previously provided to us, or if you would like to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by law), you can contact us in accordance with the “Contacting Us” section below.
In your request, please make clear what Personal Data you would like to have changed, whether you would like to have your Personal Data suppressed from our database, or other limitations you would like to put on our use of your Personal Data. For your protection, we only fulfill requests for the Personal Data associated with the email address that you use to send us your request, and we may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we often need to retain certain data for recordkeeping purposes to fulfill our legal obligations to which we are subject. Therefore, federal and/or state securities laws require us to keep records for a certain period of time before we can delete them.
We Will Keep You Informed: If our Privacy Policy is expected to change, we will notify you in advance. Your custodian has provided a copy of their Privacy Policy to you in a separate mailing. You may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection laws occurs at https://edpb.europa.eu/aboutedpb/board/members_en
Contacting Gilbert & Cook, Inc.:
Email: llcook@gilbertcook.com
Office: (515) 270-6444
5058 Grand Ridge Drive
West Des Moines, IA