Q3 Asset Management Corp., ("Q3 Asset Management) as a Registered Investment Advisory Firm, is covered under the definition of a "financial institution" under the Gramm-Leach-Bliley Act and in conjunction with State privacy rules. The privacy rules require every broker, dealer, investment company, and registered investment adviser to adopt policies and procedures reasonably designed to safeguard customer records and information. Q3 Asset Management maintains compliance with the privacy rules and takes the issue of protecting client privacy seriously.
The types of information the Adviser may collect during the normal course of business may include information provided from applications as well as forms and other information provided to us either verbally or in writing. Some of this information may include (but is not limited to) your name, address, phone number, account information, social security number, beneficiaries, employment, assets, income and debt, information about your transactions, accounts, trading activity, parties to transactions, information from other outside sources and any other information that is deemed to be nonpublic personal information as defined by the Gramm-Leach-Bliley Act and State rules.
The staff of Q3 Asset Management realizes that providing personal information is an act of trust. Q3 Asset Management values its clients' trust and confidence. The Adviser will never sell or share the nonpublic personal information we obtain from or in reference to its clients. All information provided by clients to Q3 Asset Management and its staff, and information and advice furnished to clients by the Adviser, shall be treated as confidential and shall not be disclosed to affiliated or unaffiliated third parties, except as permitted or directed by clients with written authorization, by application to facilitate the investment services offered by the Adviser via an unaffiliated financial services provider, or as required by any rule, regulation or law. State regulators routinely audit registered investment advisers to ensure adherence to compliance rules and regulations. Part of the regulator's routine examination process may include a review of client files for suitability of investments and advice provided.
Q3 Asset Management's policy to protect client information extends beyond the termination of the Engagement Letter or Client Agreement. Client records are maintained for the time period required by the securities regulators and are thereafter safely destroyed via shredding.
In instances where consumers provide nonpublic information to the Adviser but do not become clients, Q3 Asset Management also provides privacy protections. Original account or other documents are promptly returned to the consumer. Any copies of information may be maintained by the Adviser for a period of up to one year and thereafter are destroyed via shredding.
Clients may engage the services of unaffiliated investment, brokerage, custodial and insurance firms for products or services. Clients should request each specific firm's written privacy policy for review.
Q3 Asset Management maintains client records in a controlled environment and records are only available to authorized persons of the Adviser who have a need to access client information in order to deliver advisory services, perform administrative services, or respond to client requests. Clients are encouraged to discuss any questions regarding our privacy policies and procedures directly with Brad Giaimo, the President and Chief Compliance Officer of Q3 Asset Management.
