Financial companies choose how they share your personal information. Federal law gives our clients the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this “Privacy Policy Notice” carefully to understand what we do.
Protecting your private information is our priority. This Statement of Privacy applies to Saguaro Capital Management, LLC (“Saguaro”) and saguarocm.com and governs data collection and usage. For the purposes of this Privacy Policy, unless otherwise noted, all references to Saguaro Capital Management, LLC include Saguaro Capital Management, LLC and saguarocm.com. The Saguaro Capital Management, LLC website is an information site. By using the Saguaro Capital Management, LLC website, you consent to the data practices described in this statement.
Saguaro Capital Management, LLC (the “Adviser”) does not disclose nonpublic personal information about its prospective, existing or former clients to third parties other than as described below. The Adviser collects personal information about you in connection with providing advisory services to you. This information includes your social security number and may include other information such as your:
The Adviser collects this information from you through various means. For example, when you give the Adviser your contact information, enter into an investment advisory contract with the Adviser, buy securities (i.e., interests in a fund) from the Adviser, tell the Adviser where to send money, or make a wire transfer. The Adviser also may collect your personal information from other sources. The Adviser maintains physical, electronic, and procedural safeguards that comply with federal standards to safeguard your nonpublic personal information which the Adviser believes are adequate to prevent unauthorized disclosure of such information.
Additionally, in order to better provide you with products and services via our Site, Saguaro Capital Management, LLC may collect personally identifiable information, such as your:
We do not collect any personal information about you unless you voluntarily provide it to us. To wit, we will use your information for, but not limited to, communicating with you in relation to services and/or products you have requested from us. We also may gather additional personal or non-personal information in the future.
All financial companies need to share customers’ personal information to run their everyday business and the Adviser uses the personal information collected from you for everyday business purposes. These purposes may include for example:
Saguaro Capital Management, LLC collects and uses your personal information to operate its website(s) and deliver the services you have requested.
Saguaro Capital Management, LLC may also use your personally identifiable information to inform you of other products or services available from Saguaro Capital Management, LLC and its affiliates.
The Adviser may provide your personal information to firms that assist the Adviser in servicing your account and have a need for such information, such as a broker or fund administrator. The Adviser may also disclose such information to service providers and financial institutions with whom the Adviser has joint marketing arrangements (i.e., a formal agreement between financial companies that together market financial products or services to you, such as placement agents). The Adviser requires third-party service providers and financial institutions with which the Adviser has joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which the Adviser discloses the information to them. These sharing practices are consistent with Federal privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws. The Adviser notes that the Federal privacy laws only give you the right to limit the certain types of information sharing that the Adviser does not engage in (e.g., sharing any personal information with others in order for them to market to you)
To protect your personal information from unauthorized access and use, the Adviser maintains physical, electronic, and procedural safeguards that comply with Federal law to safeguard nonpublic personal information which the Adviser believes are adequate to prevent unauthorized disclosure of such information. These measures include computer safeguards and secured files and buildings. This Privacy Policy Notice relates to the following entities:
Saguaro Capital Management, LLC does not sell, rent or lease its customer lists to third parties.
Saguaro Capital Management, LLC may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Saguaro Capital Management, LLC or the site; (b) protect and defend the rights or property of Saguaro Capital Management, LLC; and/or (c) act under exigent circumstances to protect the personal safety of users of Saguaro Capital Management, LLC, or the public.
Information about your computer hardware and software may be automatically collected by Saguaro Capital Management, LLC. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Saguaro Capital Management, LLC website.
This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.
Saguaro Capital Management, LLC does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website.
Investors are provided with Saguaro’s Privacy Policy Notice initially and on an annual basis. Saguaro Capital Management, LLC reserves the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account, by placing a prominent notice on our site, and/or by updating any privacy information on this page. Your continued use of the Site and/or Services available through this Site after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy.
If you have any questions about this Privacy Notice, please contact Andy Salsky by email at asalsky@saguarocm.com
Effective as of August 31, 2022
