Privacy Policy

UNION SQUARE ADVISORS considers privacy to be fundamental to our relationship with you. We and our employees are committed to maintaining the confidentiality, integrity and security of our current and former clients’ non-public personal information. Accordingly, we have developed internal policies to protect confidentiality while allowing clients’ needs to be addressed and met.

 

We respect your right to privacy. We also know, however, that you expect us to provide our services in an efficient and accurate manner. To do so, we must collect and maintain certain non-public information about you. We collect this information for the purpose of providing the services you have asked us to provide and such other services we may, during the course of our representation of you, recommend you consider.

 

We will not disclose any non-public personal information about you, except to our affiliates and service providers as allowed by applicable law or regulation. In the normal course of serving you, information we collect may be shared with companies that perform various services on your behalf, such as our accountants, attorneys, broker-dealers or other investment managers. Specifically, we may disclose to these service providers non-public personal information including:

 

  • Information we receive on subscription agreements, new account forms or other forms, such as name address, account or tax identification number and the types and amounts of investments;
  • Information about transactions with us, our affiliates or others, such as participation in other investment programs, ownership of certain types of accounts, such as IRAs, or other account data; and;
  • Information we receive from a consumer reporting agency, such as an individual’s creditworthiness and credit history.

 

Any party that receives this information will use it only for the services required and as allowed by applicable law or regulation, and is not permitted to share or use this information for any other purpose. To protect the personal information of individuals, we permit access only by authorized employees who need access to that information to provide services to you. In order to guard your non-public personal information, we maintain physical, electronic and procedural safeguards. An individual’s right to privacy extends to all forms of contact with us, including telephone, written correspondence and electronic media, such as the internet.

Business Continuity Plan

UNION SQUARE ADVISORS has established a business continuity plan (BCP) to address how the Firm will respond to external or unforeseen events that could temporarily cause the interruption of our business operations. This BCP is designed protect our employees, our clients and our partners by reducing the impact of such interruptions.

 

Based on the BCP, UNION SQUARE ADVISORS creates duplicate copies of all critical information – including Firm, client and regulatory information – on physical and/or electronic media, and stores these backup copies at remote locations. We conduct tests of our BCP procedures to ensure that this information stored offsite continues to be available to the Firm, and that it remains accurate. Certain of our software and communications systems and data are hosted and stored in secure, remote facilities, which provides additional protection for critical information should a business disruption occur at one of our principal office locations. We and our partners monitor these facilities, the equipment and systems operating there, the associated business data, and our communications access thereto, on an ongoing basis. We also maintain password and other networking and system security policies and procedures in order to prevent unauthorized access to these systems and data.

 

In the event of a business disruption that prevents our employees from accessing or using one or more of our office locations, UNION SQUARE ADVISORS has established policies and procedures for communicating with employees and for determining if and how they can perform essential business operations from an alternate location on a temporary basis. UNION SQUARE ADVISORS will make the decision to conduct operations from an alternate location as soon as practicable following a business disruption, based on the nature and severity of the precipitating event, and we will utilize various electronic, telephonic and physical means to communicate our operational status to our clients. Updates regarding our operational status will be posted on our website at www.usadvisors.com.

 

Business continuity planning is a continuous process. While no such plan can address every possible eventuality, we regularly evaluate our policies and procedures to ensure their effectiveness and comprehensiveness. Updates will be posted on our website and made available to clients upon written request.

CIP

Important Information You Need to Know about Opening a New Account


To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify and record information that identifies each person who opens an account.

This notice answers some questions about your firm's Customer Identification Program.

 

What types of information will I need to provide?

 

When you open an account, your firm is required to collect the following information:

  • Name
  • Date of birth
  • Address
  • Identification number:
  • U.S. citizen: taxpayer identification number (Social Security number or employer identification number)
  • Non-U.S. citizen: taxpayer identification number; passport number and country of issuance; alien identification card number; or government-issued identification showing nationality, residence and a photograph of you.

‚ÄčYou may also need to show your driver's license or other identifying documents.

 

A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement or a trust agreement.

 

U.S. Department of the Treasury, Securities and Exchange Commission, FINRA, and New York Stock Exchange rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience and objectives and risk tolerance.