Privacy Policy

SUMMIT GLOBAL INVESTMENTS, LLC will not disclose a client’s Non-public Personal Information to anyone unless it is permitted or required by law, at the direction of a client, or is necessary to provide requested services.

Procedures

  1. SUMMIT GLOBAL INVESTMENTS, LLC shall not sell Non-public Personal Information to anyone.
  2. GLOBAL INVESTMENTS, LLC will restrict access to Non-public Personal Information to individuals within SUMMIT GLOBAL INVESTMENTS, LLC who require the information in the ordinary course of servicing clients’ accounts. Clients’ Non-public Personal Information is used only for business purposes.
  3. SUMMIT GLOBAL INVESTMENTS, LLC has developed procedures to safeguard client records and Non-public Personal Information (See Attachment A).
  4. Non-public Personal Information may only be given to third-parties under the following circumstances:
    • To broker/dealers to open a client’s brokerage account;
    • To other firms as directed by clients, such as accountants, lawyers, etc.;
    • To specified family members (as authorized by law and/or the client);
    • To third-parties as needed to provide requested services; and
    • To regulators and others, when required by law.
  5. At times, Non-public Personal Information may be reviewed by SUMMIT GLOBAL INVESTMENTS, LLC’s outside service providers (i.e. – accountants, lawyers, consultants, etc.). SUMMIT GLOBAL INVESTMENTS, LLC will review the entities’ privacy policies.
  6. SUMMIT GLOBAL INVESTMENTS, LLC shall provide a privacy notice (See Attachment B) to clients (i.e. “natural persons”) upon Inception of the relationship and annually thereafter. SUMMIT GLOBAL INVESTMENTS, LLC will maintain a record of the dates when the privacy notice is provided to clients.
  7. In the event of a change in the privacy policy, SUMMIT GLOBAL INVESTMENTS, LLC will provide its clients with a sufficient amount of time to opt out of any disclosure provisions.
  8. Any suspected breaches to the privacy policy must be reported to the Compliance Officer.
  9. If an Employee receives a complaint regarding a potential identity theft issue (be it from a client or other party), the Employee should immediately notify the Compliance Officer. The Compliance Officer will thoroughly investigate any valid complaint, and maintain a log of all complaints as well as the result of any investigations.
  10. In the event that unintended parties receive access to Non-public Personal Information of California residents, SUMMIT GLOBAL INVESTMENTS, LLC will promptly notify those clients of the privacy breach. See Senate Bill No. 1386.

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