Effective March 31, 2018
Our Commitment to You
Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Claro (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implement controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you.
Claro does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy.
Why you need to know
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information.
The Information We Collect From You
You typically provide personal information when you complete the paperwork required to become our Client. This information may include your:
- Social Security or Taxpayer Identification Number
- Name, Address, and Phone Numbers
- Email Address(es)
- Account Information (including other institutions)
- Assets and Liabilities
- Income and Expenses
- Investment Activity
- Investment Experience and Goals
In addition, we may collect non-public information about you from other sources.
- Custody, brokerage, and advisory agreements
- Other advisory agreements and legal documents
- Transactional information with us or others
- Account applications and forms
- Investment questionnaires and suitability documents
- Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained in their responsibilities to protect clients' personal information.
We require third parties that assist in providing our services to you to protect the personal information they receive from us.
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information.
Basis For Sharing
Servicing our Clients
We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Marketing Purposes
Claro does not disclose and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Claro or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes.Authorized Users
Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent(s) or representative(s).
Information About Former Clients
Claro does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients.
In response to a Massachusetts law, clients must “opt-in” to share non-public personal information with non-affiliated third parties before any personal information is disclosed. We may disclose non-public personal information to other financial institutions with whom we have joint business arrangements for proper business purposes in connection with the management or servicing of your account.
We'll Keep You Informed