Heritage Capital Research is committed to maintaining the trust and confidence of our customers. We want you to understand how we protect your privacy when we collect and use information about you and the measures we will take to safeguard that information. The following statement provides a description of our practices and policies.

What is nonpublic personal information?

Nonpublic personal information includes social security numbers, driver license numbers, images of your personal signatures, passwords, account numbers and other personal identification numbers, account balances and account transaction history.

How we collect your nonpublic personal information

We may collect nonpublic, personal information in connection with establishing your account and/or providing investment advisory services. This information will generally be derived from information we receive from you on the Client Questionnaire or other forms, and from information about your transactions with us or other advisers. We assume that the client’s email system is not secure, and do not recommended its use for nonpublic personal information.

How your nonpublic personal information is used?

Your nonpublic and personal information such as employment and income are used to establish your identity for Patriot Act compliance, for account applications and tax related documentation, and for assistance verification. Trading, portfolio holdings and other information are used for compliance reviews, securities filings and beneficial claims. If you are an employee or director of a publicly traded company your account activity may be made available to your employer and industry regulators.

How we protect the confidentiality of your information?

We restrict access to your nonpublic, personal and account information to our employees and third party service providers on a “need-to-know” basis. Our personnel are educated about the importance of confidentiality and client privacy and attest to our Code of Ethics and Policies and Procedures to protect your information. Any service providers utilized are also required to safeguard your information and use it only for authorized purposes. We maintain and ensure physical, electronic, and procedural safeguards to guard your non-public personal information and will not disclose any nonpublic information about our clients or former clients to anyone, except as permitted or required by law.

Should you have any questions about our privacy program, you may contact us.