CUSTOMER PRIVACY POLICY NOTICE

In November of 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA).  The GLBA requires certain financial institutions, such as investment advisor firms, to protect the privacy of customer information.  Federal law gives clients the right to limit some but not all sharing of your personal information. In situations where a financial institution does disclose customer information to nonaffiliated third parties, other than permitted or required by law, clients must be given the opportunity to opt out or prevent such disclosure.  Hamilton Capital Advisors, LLC and its Affiliates (collectively, “Hamilton Capital Advisors,” “we,” “our,” or “us“) does not share or disclose customer information to nonaffiliated third parties except as permitted or required by law.

COMMITMENT TO YOUR PRIVATE INFORMATION.

Hamilton Capital Advisors is committed to safeguarding the confidential information of its clients.  Hamilton Capital Advisors holds all personal information provided by clients in the strictest confidence and it is the objective of the firm to protect the privacy of all clients.  Except as permitted or required by law, Hamilton Capital Advisors does not share confidential information about clients with nonaffiliated parties.  In the event that there were to be a change in this policy, the firm will provide clients with written notice and clients will be provided an opportunity to direct Hamilton Capital Advisors as to whether such disclosure is permissible.

WHY WE COLLECT AND HOW WE USE INFORMATION.

To conduct regular business, Hamilton Capital Advisors, may collect personal information from sources such as:

• Information reported by the client on applications or other forms the client provides to us
• Information about the client’s transactions implemented by the firm or others
• Information developed as part of financial plans, analyses or investment advisory services

To administer, manage, service, and provide related services for client accounts, it is necessary for Hamilton Capital Advisors to provide access to customer information within the firm and to nonaffiliated companies, with whom the firm has entered into agreements with.  To provide the utmost service, we may disclose the information below regarding clients and former clients, as necessary, to companies to perform certain services on our behalf.

• Information Hamilton Capital Advisors receives from the client on applications (name, social security number, address, assets, etc.)
• Information about the client’s transactions with the firm or others (account information, payment history, parties to transactions, etc.)
• Information concerning investment advisory account transactions
• Information about a client’s financial products and services transaction with Hamilton Capital Advisors

SHARING INFORMATION WITH OTHER COMPANIES PERMITTED UNDER LAW.

Since Hamilton Capital Advisors shares nonpublic information solely to service client accounts, the firm does not disclose any nonpublic personal information about the firm’s clients or former clients to anyone, except as permitted by law.  However, the firm may also provide customer information outside of the firm as required by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas. Additionally, Hamilton Capital Advisors does not jointly market with affiliated or nonaffiliated companies.

In the event that Hamilton Capital Advisors has a change to its customer privacy policy that would allow it to disclose nonpublic information not covered under applicable law, we will allow clients the opportunity to opt out of such disclosure.

Entities with whom Hamilton Capital Advisors may share nonpublic information includes affiliated companies, such as our tax, legal, and insurance affiliates and non-affiliated companies, e.g. custodian. Information is shared so that your account can be opened at the custodian and to enhance our service offering to you by consulting with our tax, legal, and insurance affiliates, as necessary, to provide you with accurate and timely advice on your financial situation.  We may also share your non-public information with parties acting at your request and on your account.

HOW WE PROTECT YOUR INFORMATION

Hamilton Capital Advisors and its affiliates maintain a comprehensive information security program designed to ensure the security and confidentiality of customer information, protect against threats or hazards to the security of such information and prevent unauthorized access. This program includes:

• Procedures and specifications for administrative, technical and physical safeguards.
• Security procedures related to the processing, storage, retention and disposal of confidential information.
• Programs to detect, prevent and, when necessary, respond to attacks, intrusions or unauthorized access to confidential information.
• Restricting access of customer information to employees who need to know that information to provide products and services to you, and appointing specific employees to oversee our information security program

CHILDREN.

Our web site is not directed to children under the age of 18 years. By using our website, you represent and warrant that you are at least 18 years old.

We respect the privacy of children and do not knowingly collect or retain personally identifiable information or nonpublic information from children under the age of 18 through our web site. However, we may process nonpublic information, on a child’s behalf, with permission from the parent or guardian.

To the extent we have unintentionally collected any nonpublic information on our website from a person under the age of 18 years old, you may request and obtain removal of this nonpublic information. To make such a request, please send an email with a detailed description of the specific content or information to the e-mail address below.

Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

FORMER CUSTOMERS.

Even if we cease to provide you with financial products or services, our Privacy Policy will continue to apply to you and we will continue to treat your nonpublic information with strict confidentiality.

RESIDENTS OF THE EUROPEAN UNION (EU).

Residents of the EU can find Hamilton Capital Advisors’s General Data Protection Regulation (GDPR) Privacy Policy Notice by clicking here.

RESIDENTS OF GEORGIA

Under the Georgia Consumer Financial Protection Bureau of 2011 (the “CFPB”), Georgia residents have certain rights around Hamilton Capital Advisors’ collection, use and sharing of their personal information. Georgia residents, please click here to read our Georgia Consumer Privacy Notice.

CHANGES TO THIS POLICY.

Hamilton Capital Advisors will provide each client with initial notice of the current Privacy Policy when the client relationship is established.  Additionally, Hamilton Capital Advisors may occasionally amend this Privacy Policy at any time. If we decide to use personal information in a manner that is materially different from that stated at the time it was collected, we will notify you of such changes prior to implementing them by posting a revised Privacy Policy with a new “Last Updated” date. Hamilton Capital Advisors shall also provide each client with the current Privacy Policies at least annually.

We encourage you to check our website frequently to see when this Privacy Policy was last revised and to be informed of how we are committed to protecting your information.

ANY QUESTIONS.

If there are any questions, regarding this US Privacy Policy Notice, please see the Contact Us section below to reach out to us via email or phone.