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Federal law requires financial institutions to inform clients of their policies relating to the protection of personal financial information. The following statement explains how IEQ Capital handles the information that we receive about our clients. IEQ Capital is committed to protecting the privacy and confidentiality of non-public personal customer information. Personal information is any data that identifies clients or their accounts.


Information Collection

IEQ Capital may collect personal information through submission of account documentation and contact information on forms completed by the client, or client’s authorized representative. Such information could include the client’s name, e-mail and postal address, phone number, Social Security number, assets, income, financial needs and goals, account balances and transactions, including those with unaffiliated third parties. We use this information only to process your requests and transactions and to provide you with financial advice. We restrict access to nonpublic personal information about you to those IEQ Capital employees who need to know that information to provide services to you.


Information Use

It is IEQ Capital’s policy not to disclose non-public information about our clients to any other parties except where required by law or authorized by the client’s, or authorized client’s representative, or according to our Privacy Policy. From time to time, IEQ Capital may disclose personal information collected from clients to third-party service providers that facilitate the operation of some areas of our investment advisory business, and IEQ Capital may also use such information in the account intake process, including conducting anti-money laundering screening. We require any third-party service providers to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them.


Safeguards

IEQ Capital uses the following measures to protect the privacy of clients. All personal information in our computers is protected from unauthorized access by a secure firewall and database architecture. In instances where personal information is exchanged via the internet, electronic and procedural methods to safeguard this exchange are used.

It is the policy of the Firm to ensure so called “consumer report information” (such as personal information about a client, e.g., Social Security number) is protected, maintained and disposed of in ways that ensure such information is safeguarded from unauthorized uses or disclosures. IEQ Capital will take reasonable measures to dispose of personal information so that it cannot be read or reconstructed for unauthorized use. IEQ Capital will determine the appropriate method of disposal on an as needed basis.


Service Providers

IEQ Capital may have relationships with non-affiliated third parties that require us to share customer information in order for the third party to carry out its services for us.


Processing and Servicing Transactions

IEQ Capital may share information when it is necessary to effect, administer, or enforce a transaction for our clients or if a client initiates a request for us to share information with an outside party. All requests by clients must be received in writing from the client.


Sharing as Permitted or Required by Law

IEQ Capital may disclose information to non-affiliated third parties as allowed by law. For example, this may include a disclosure in connection with a subpoena or similar legal process, a fraud investigation, recording of deeds of trust and mortgages in public records, an audit or examination, or the sale of an account to another financial institution.


California Consumer Privacy Act (“CCPA”)

You may have certain rights granted to you if your personal information is protected by the California Consumer Privacy Act of 2018 (“CCPA”):

You may have the right to request that we delete any personal information that we have about you. You may call us at (650) 581-9807 or email us at privacy@ieqcapital.com with “CCPA Right to Delete” in the subject line and in the body of your message to exercise this right.

You may have the right to request from us:

You may call us at (650) 581-9807 or email us at privacy@ieqcapital.com with “CCPA Right to Know” in the subject line and in the body of your message to exercise this right.

There are circumstances where we are not required to comply with consumer requests and we will let you know if one of those situations arises.

We do not sell your personal information.

We reserve the right to verify your identity before we process any request relating to your personal information. We verify identify by comparing information we have on file against information you may provide us.

California residents may not be discriminated against for exercising any of the rights described above.