Information that We Collect
All nonpublic information that we obtain is either collected because we are required by law to do so or because we think such information is necessary to administer your account(s) and serve your needs. We have described below the sources from which we obtain nonpublic information and the types of nonpublic information that we gather.
- Applications and Other Forms. When you open an investment advisory or brokerage relationship with us or we provide a service to you, we collect information on your investor questionnaire and account opening forms that may be necessary to open your account and provide services to you. As well as your name, address and telephone number, we collect a variety of additional information including your social security number, age, income, net worth, investable assets, current investments and portfolio objectives.
- In the course of servicing and administering your account(s) or service(s), Brinker Capital collects nonpublic information concerning your transactions. For example, as applicable, we gather and maintain information regarding your transactions, including securities bought and sold, balances, positions, transfers, and account history.
- Third Parties. We may verify from outside sources information regarding your identity, income or assets.
Protection of the Information that We Collect
Brinker Capital values your trust and realizes that an important element in maintaining that trust is our ability to safeguard your personal information from unauthorized disclosure, even after your relationship with us ends. Below we describe how we protect the confidentiality and security of your information.
- Restricted Access and Employee Training. Authorization to access your personal information is given only to those of our employees and agents who need to know such material in order to provide you with Brinker Capital’s products and services and those persons authorized by you to receive such information. Recipients of your information are required to safeguard your information and hold it in the strictest of confidence. Privacy policies and procedures are an integral part of our employee training program.
- Operational Safeguards. We implement and maintain physical, electronic and internal procedural safeguards to protect your information.
Information Disclosed within the Brinker Family
Brinker Capital Investments LLC and Brinker Capital Securities LLC (the “Brinker Family”) may share the nonpublic information concerning you for the following purposes:
- To Better Serve Your Needs. Information is shared within the Brinker Family in order to provide you with the best combination of financial services to accommodate your financial needs and to keep you informed about Brinker Capital product offerings that may be appropriate for you.
- To Comply with Laws. We also share certain information within the Brinker Family in order to comply with applicable laws and regulations.
Information Disclosed to Third Parties
Unless you have specifically requested that we do so, we do not share any of your nonpublic information with parties unaffiliated with Brinker Capital other than as described below.
- In order to provide the services to you and process your transactions, it is necessary from time to time for us to disclose your information to investment managers, custodians, clearing firms, solicitors and representatives and other companies that provide certain services to us, including, for example, the printing and mailing of your account statement(s). Our agreements with such companies require that they comply with privacy laws.
- We may disclose nonpublic information concerning you to government agencies and regulatory organizations where we believe in good faith that the disclosure is required or permitted by law.
Policy for “Householding” Client Reports
Some clients prefer to receive performance and other information related to their Brinker Capital account on both an individual basis and combined with related accounts (e.g., a married couple’s joint account combined with the IRA accounts of each spouse). Brinker Capital will present such information on both an individual and a combined basis (i.e., “household” such reports) in the following circumstances:
- Actual Consent. Brinker Capital may present such information on both an individual and a combined basis if you have authorized Brinker Capital to do so in your investment advisory agreement or by a separate written consent. Brinker Capital will provide household reports if you specifically request them.
- Implied Consent. Brinker Capital will “household” reports for clients that share the same address and whom Brinker Capital reasonably believes are members of the same family, if your solicitor or financial advisor specifically authorizes Brinker Capital to do so AND you do not object to receiving household reports after written notice from Brinker Capital that it intends to household future reports. If you do not object to receiving household reports after receiving such notice, you will be deemed to have consented to the distribution of information regarding your account to the other Brinker Capital clients included in the household report (all of whom must share your address).
- Revocation of Consent. If you have provided a separate actual consent or are deemed to have given implied consent, you may revoke your consent to receiving household reports at any time.
Additional Information for California Residents. The California Consumer Privacy Act of 2018 (“CCPA”) gives residents of California additional rights with respect to certain personal information that we may collect. If you are a California resident, please read our CCPA Disclosure.