INOVE Asset Management Privacy Policy

Privacy Policy

INOVE recognizes and respects the privacy of each of its customers and their expectations for confidentiality. The protection of customer information is of fundamental importance in our operation and INOVE takes seriously its responsibility to protect nonpublic personal information.

INOVE collects, retains and uses information that assists INOVE in providing the best service possible. This information comes from the following sources:

• Account agreements and other required forms
• Written, oral, electronic or telephonic communications and
•  Account and transaction histories with us, our affiliates, or others

INOVE does not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law. INOVE restricts access to nonpublic personal information about you to those employees, affiliates, and service providers who need to know that information to provide INOVE products or services to you. INOVE requires that these entities limit the use of the information provided to the purposes for which it was disclosed and as permitted by law.

INOVE maintains physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

Participation or Interest in Client Transactions and Personal Trading

It is the express policy of INOVE that no person employed by INOVE may purchase or sell any security prior to a transaction(s) being implemented for an advisory account, and therefore, preventing such employees from benefiting from transactions placed on behalf of advisory accounts. INOVE employees may buy or sell securities identical to those recommended to customers for their personal accounts. As these situations represent a conflict of interest, INOVE has established the following restrictions in order to ensure its fiduciary responsibilities:

1. A director, officer or employee of INOVE shall not buy or sell securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry. No person of INOVE shall prefer his or her own interest to that of the advisory client.
2. INOVE maintains a list of all securities holdings for itself, and anyone associated with this advisory practice with access to advisory recommendations. These holdings are reviewed on a regular basis by an appropriate officer/individual of INOVE.
3. INOVE emphasizes the unrestricted right of the client to decline to implement any advice rendered, except in situations where INOVE is granted discretionary authority of the client’s account.
4. INOVE emphasizes the unrestricted right of the client to select and choose any broker or dealer, and/or insurance company(s) he/she wishes.
5. INOVE requires that all individuals must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices.
6. Any individual not in observance of the above may be subject to termination.