Delivering More Than Results

Aaron Brett

Aaron Brett considers customer privacy to be a fundamental aspect of its relationship with clients. Aaron Brett is committed to maintaining the confidentiality, integrity, and security of its current, prospective and former clients’ non-public personal information. Aaron Brett has developed policies that are designed to protect this confidentiality, while allowing client needs to be served.

In the course of providing its clients with products and services, Aaron Brett and certain of its service providers may obtain non-public personal information about its clients. This information may come from sources such as account applications and other forms, from other written, electronic or verbal correspondence, from client transactions, from client brokerage or financial advisory firm, financial adviser or consultant, and/or from information captured on applicable websites.
As a matter of policy, Aaron Brett does not disclose any non-public personal information provided by its clients or gathered by Aaron Brett to non-affiliated third parties, except as required or permitted by law or for Aaron Brett’s everyday business purposes, such as to process transactions or service a client account. As is common in the industry, non-affiliated companies may from time to time be used to provide certain services, such as preparing and mailing prospectuses, reports, account statements and other information, conducting research on client satisfaction, and gathering shareholder proxies. Aaron Brett (or its affiliates) may also retain non-affiliated companies to market its products, and may enter into joint marketing arrangements with them and other companies. These companies may have access to client personal and account information, but are permitted to use the information solely to provide the specific service or as otherwise permitted by law. Aaron Brett may also provide client personal and account information to their brokerage or financial advisory firm and/or to their financial adviser or consultant.
Aaron Brett reserves the right to disclose or report personal or account information to non-affiliated third parties in limited circumstances where Aaron Brett believes in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities, to protect its rights or property, or upon reasonable request by any of its mutual funds in which clients have invested. In addition, Aaron Brett may disclose information about a client or their accounts to a non-affiliated third party at their request or if the client consents in writing to the disclosure.
Aaron Brett may share client information with its affiliates in connection with servicing a client account, and subject to applicable law may provide a client with information about products and services that Aaron Brett or its affiliates believe may be of interest to the client. The information that Aaron Brett may share may include, for example, information about Aaron Brett’s or its mutual funds’ experiences and transactions with a client, their participation in its mutual funds or other investment programs, their ownership of certain types of accounts, information captured on applicable websites, or other data about their accounts, subject to applicable law. Aaron Brett’s affiliates, in turn, are not permitted to share client information with non-affiliated entities, except as required or permitted by law.
Aaron Brett takes seriously the obligation to safeguard a client’s non-public personal information. In addition to this policy, Aaron Brett has implemented procedures that are designed to restrict access to a client’s non-public personal information to its personnel who need to know that information to perform their jobs, such as servicing a client’s account or notifying a client of new products and services. Physical, electronic, and procedural safeguards are in place to guard a client’s non-public personal information.
Websites maintained by Aaron Brett or its service providers may use a variety of technologies to collect information that help Aaron Brett and its service providers understand how the website is used. Information collected from a client’s web browser (including small files stored on a client’s device that are commonly referred to as “cookies”) allow the websites to recognize a client’s web browser and help to personalize and improve a client’s user experience and enhance navigation of the website. In addition, Aaron Brett or certain of its service providers may use third parties to place advertisements for Aaron Brett products on other websites, including banner advertisements. Such third parties may collect anonymous information through the use of cookies or action tags (such as web beacons). The information these third parties collect is generally limited to technical and web navigation information, such as a client’s IP address, web pages visited and browser type, and does not include personally identifiable information such as name, address, phone number or email address. If a client is a registered user of Aaron Brett’s website, Aaron Brett or its service providers or third party firms engaged by Aaron Brett or its service providers may collect or share the information a client submits to us, which may include personally identifiable information. This information can be useful to Aaron Brett when assessing and offering services and website features for a client. A client can change their cookie preferences by changing the setting on their web browser to delete or reject cookies. If a client deletes or rejects cookies, some website pages may not function properly. Aaron Brett does not look for web browser “do not track” requests.
From time to time, Aaron Brett may update or revise this privacy policy. If there are changes to the terms of this privacy policy, documents containing the revised policy on the relevant website will be updated.