Privacy Policy

What You Should Know

We recognize the importance of keeping information about you secure and confidential. We do not sell or share your non-public personal and financial information with marketers or others outside our affiliated group of companies.

We carefully manage information among our service partners to safeguard your privacy and to provide you with consistently excellent service.

We are providing this notice to you to comply with the requirements of Regulation S-P, "Privacy of Consumer Financial Information," issued by the United States Securities and Exchange Commission.

Privacy Policy

Chautauqua Capital Management is committed to protecting the non-public personal and financial information of customers and consumers who obtain or seek to obtain financial products or services primarily for personal, family or household purposes. This commitment is fulfilled by establishing and implementing policies and systems to protect the security and confidentiality of this information.

Access to non-public personal and financial information about you is limited to those personnel who need to know the information in order to provide products or services to you. Physical, electronic and procedural safeguards are maintained to protect your non-public personal and financial information.

Categories Of Information Collected

The following types of non-public personal and financial information about you from the following sources:

Your name, address and identifying numbers, and other personal and financial information, from you and from identification cards and papers you submit to us, on applications, subscription agreements or other forms or communications.

Information about your account balances and financial transactions with us, our affiliated entities, or non-affiliated third parties, from our internal sources, from affiliated entities and from non-affiliated third parties.

Information about your account balances and financial transactions and other personal and financial information, from consumer credit reporting agencies or other non-affiliated third parties, to verify information received from you or others.

Categories Of Information Disclosed To Non-Affiliated Third Parties

Your name, address and account and other identifying numbers, as well as information about your pending or past transactions and other personal financial information, may be disclosed to non-affiliated third parties, as necessary to execute, process, service and confirm your securities transactions, to administer and service your account and commingled investment vehicles in which you are invested, or to market our products and services through joint marketing arrangements.

Non-public personal and financial information concerning you may be disclosed to law enforcement agencies, federal regulatory agencies, self-regulatory organizations or other non-affiliated third parties, if required or requested to do so by a court order, judicial subpoena or regulatory inquiry.

Your non-public personal and financial information to non-affiliated third parties is not disclosed, except where we believe in good faith that disclosure is required or permitted by law. Because your non-public personal and financial information to non-affiliated third parties is not diclosed, our Customer Privacy Policy does not contain opt-out provisions.

Categories Of Information We Disclose To Our Affiliated Entities

Your name, address and account and other identifying numbers, account balances, information about your pending or past transactions and other personal financial information may be disclosed to our affiliated entities for any purpose.

Your name, address and account and other identifying numbers, account balances and information about your pending or past transactions will be disclosed regularly to our affiliates to execute, process and confirm securities transactions for you, to administer and service your account and commingled investment vehicles in which you are invested, or to market our products and services to you.

Information About Former Customers

Non-public personal and financial information about former customers will not be disclosed to non-affiliated third parties unless required or requested by a court order, judicial subpoena or regulatory inquiry, or otherwise where we believe in good faith that disclosure is required or permitted by law.

Questions

Should you have any questions about this Customer Privacy Policy, please contact us by email or regular mail.

Reminder About Chautauqua Capital Management’s Financial Products

Financial products offered by Chautauqua Capital Management:

Are not guaranteed by a bank;
Are not obligations of Chautauqua Capital Management;
Are not insured by the Federal Deposit Insurance Corporation; and
Are subject to investment risks, including possible loss of the principal amount committed or invested, and earnings thereon.