FSI Capital, LLC

FSI Capital, LLC

Privacy Policy

FSI Capital Holdings, LLC and its affiliates (collectively, “FSI”) value your privacy rights. In the course of FSI’s investment advisory activities, FSI may gain access to personally identifiable information about clients of FSI or customers of FSI’s clients (“Client Information”). All Client Information, whether relating to FSI’s current or former clients, is subject to this Privacy Policy. Any doubts about the confidentiality of information must be resolved in favor of confidentiality. Please take a moment to review our Privacy Policy. By visiting our website, you consent to this Privacy Policy.

1. Client Information

If you contact us through our website (using the Contact Us page), we will ask for and collect your name, company name, address, city, state, zip/postal code, country, email address, phone number, fax number, and any other information that you choose to provide to us.

Registered users may access a private section of our website that requires entry of a username and password. We collect that username and password both when you register and whenever you access the private section of the website.

We also collect general non-personal information about you when you visit our website, such as whether you have accessed the page before and the time of your last visit. Further, if you log into the private section of our website, we separately track your navigation within that section of our website. If we use such data at all it will be on an aggregate basis, and we will not disclose to third parties any information that could be used to identify you personally.

We track such access through a “cookie”, which is a small file stored on your computer’s hard drive. A cookie allows us to determine that a visit has occurred within our site, as well as which pages were viewed. You can decide if and how your computer will accept cookies by configuring the preferences option within your web browser. If you choose to decline cookies, however, some of the functionality of this website might be impaired.

2. Non-Disclosure of Client Information

We do not share Client Information with any third parties, except in the following circumstances:

(i) As necessary to provide the service that the client requested or authorized, or to maintain and service the client’s account. We will require that any financial intermediary, agent or sub-contractor utilized by us (such as brokers, fund administrators, attorneys or auditors) comply with substantially similar standards for non-disclosure and protection of Client Information and use the information provided by us only for the performance of the specific service requested by us.

(ii) As required by regulatory authorities or law enforcement officials who have jurisdiction over us, or as otherwise required by any applicable law.

(iii) To the extent reasonably necessary to prevent fraud, unauthorized transactions or liability.

We do not sell any Client Information to third parties for their marketing purposes. We will not send you e-mail messages without first receiving your permission, unless it relates to servicing your account or unless you have consented to receive such messages. It is our policy to include instructions for unsubscribing from these permission-based programs.

Our employees are prohibited, either during or after termination of their employment with FSI, from disclosing Client Information to any person or entity outside FSI, including family members, except under the circumstances described above. An FSI employee is permitted to disclose Client Information only to such other FSI employees who need to have access to such information to deliver our services to the client. Our employees are prohibited from making unauthorized copies of any documents or files containing Client Information and, upon termination of their employment, must return all such documents. Any employee who violates the non-disclosure policy may be subject to disciplinary action, including possible discharge, whether or not he or she benefited from the disclosed information.

3. Security of Client Information

We restrict access to Client Information to those employees who need to know such information to provide services to clients. Files containing Client Information shall be maintained in a secure area. All electronic or computer files containing any Client Information shall be password secured and firewall protected from access by unauthorized persons.

4. Privacy Notices

We will provide each client with initial notice of our current Privacy Policy at the time the client relationship is established. We will also provide each client with a new notice of our current Privacy Policy at least annually.

5. Change in Corporate Control

In the event of a corporate change in control resulting from, for example, a sale to or merger with another entity, or in the event of a sale of assets, we reserve the right to transfer your personal information to the new party in control or the party acquiring assets.

6. Changes to This Privacy Policy

We reserve the right, in our sole discretion, to change, modify, add, remove or otherwise update this policy at any time and you agree to be bound by such changes, modifications, additions, removals or updates. Your continued use of our website constitutes your agreement to this privacy statement and any updates. We encourage you to periodically review this privacy statement to stay informed about how we are protecting the information we collect.