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PRIVACY POLICY
 

As a registered investment adviser, Peak53 Partners, LP (“PEAK53”) has a responsibility and fiduciary duty to protect the privacy of client information. PEAK53 complies with SEC Regulation S‐P, which requires registered investment advisers to adopt policies and procedures to protect clients’ nonpublic personal and financial information (“NPFI”). To comply, PEAK53 holds both the firm and its employees to the highest standards of trust and fiduciary duty in the safeguarding and use of clients’ NPFI. PEAK53 is committed to maintaining the confidentiality of the information it collects from current, potential and former clients and therefore PEAK53 adheres to the policies and practices described in this notice.

Client Information

In order to provide clients with personalized financial services, PEAK53 requests nonpublic personal, financial and transactional information. PEAK53 will collect this confidential information from clients directly through conversations, paperwork and correspondence so PEAK53 can compile a full financial picture in order to best serve the client.

Disclosure of Client Information

PEAK53 maintains safeguards to comply with federal and state standards to safeguard each client’s NPFI. PEAK53 does share NPFI with nonaffiliated third parties, in the following circumstances:

  • As necessary to provide services the client has requested or authorized, or to maintain and service the client’s account;

  • With outside solicitors that provide clients with separate non-investment advisory services, in instances where the client was referred to PEAK53 by the solicitors for advisory services and would have signed a disclosure acknowledgment as to this arrangement;

  • As required by regulatory authorities or law enforcement officials who have jurisdiction over PEAK53, or as otherwise required by an applicable law;

  • To protect the confidentiality or security of the financial institution’s records against fraud and for institutional risk control purposes; and

  •  To provide information to the firm’s attorneys, accountants and auditors or others determining compliance with industry standards.


Safeguarding Client Information

PEAK53 restricts access to NPFI to those employees who need to know such information in order to provide services to clients. PEAK53 maintains physical, electronic and procedural safeguards to restrict the access to such information. Employees are prohibited, either during or after termination of employment, from disclosing NPFI to any person or entity outside PEAK53, including family members, except under the circumstances described above.

​PEAK53’s Privacy Policy remains in effect at all times, even after the client relationship is terminated.

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