Effective Date: April 10, 2019
Our Commitment to You
Hamilton Investment Counsel, LLC (“Hamilton” or the “Advisor”) is committed to safeguarding the use of personal
information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as
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. Hamilton (also referred to as “we”,
“our” and “us”) protects the security and confidentiality of the personal information we have and implements
controls to ensure that such information is used for proper business purposes in connection with the
management or servicing of our relationship with you.
Hamilton 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.
What information do we collect from you?
|What we collect||Why we collect it|
|Social security or taxpayer identification number||Assets and liabilities|
|Name, address and phone number(s)||Income and expenses|
|E-mail address(es)||Investment activity|
|Account information (including other institutions||Investment experience and goals|
What information do we collect from other sources?
|What we collect||Why we collect it|
|Custody, brokerage and advisory agreements||Account applications and forms|
|Other advisory agreements and legal documents||Investment questionnaires and suitability documents|
|Transactional information with us or others||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 on their responsibilities to
protect Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they
receive from us.
|Basis For Sharing||Do we share?||Can you limit?|
|Marketing Purposes Hamilton 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 Hamilton 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.||No||Not Shared|
|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).||Yes||Yes|
|Information About Former Clients Hamilton 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.||No||Not Shared|
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.
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy, and will provide you with a revised policy if the changes materially alter
personal information other than as described in this notice unless we first notify you and provide you with an
opportunity to prevent the information sharing.
contacting us at (678) 802-4960