Elstree may receive personal and financial information (“nonpublic personal information”) with from you. We respect your right to privacy. We understand that you have entrusted us with this private information and we recognize the importance of protecting unnecessary or unauthorized access to it.

I. Information that we collect

We may collect nonpublic personal information about you when you communicate or transact business with us or with our service providers in writing, electronically or by telephone. For example, we collect nonpublic personal information (such as name, address, account and other investment information) about you from the following sources:

• Applications or forms completed by you
• Information you provide during telephone conversations, email, or contact forms that you send us; and
• Your transactions and investments with us, or others (including, for example, your own broker or custodian).
  
  

II. Information that we disclose

We do not sell or rent your nonpublic personal information to any third parties.

We may disclose your nonpublic personal information to third parties in the following limited circumstances:

• We may disclose some or all of your nonpublic personal information to companies that help us maintain, or service your investment, including companies that perform administrative, accounting,or other services for us.
• We may disclose some or all of your nonpublic personal information, such as account and transaction data, to companies that assist us in marketing or client servicing. These companies will use this information only for the services for which we hired them, are not permitted to use or share this information for any other purpose and are required to protect the confidentiality and security of this information.
• We may disclose or report some or all of your nonpublic personal information if you request or authorize us to do so, for institutional risk control, or in other circumstances where we believe in good faith that disclosure is required or permitted under law.
  
  

III. Our security procedures

We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information. Access to such information is limited to those employees who need it to perform their jobs, such as servicing your accounts, resolving problems or informing you of new products or services

If you identify any inaccuracy in your personal information or you need to make a change to that information, please contact us in writing so that we may promptly update our records.