Our Commitment to You

Charter Oak Capital Management, LLC (“Charter Oak”) is committed to safeguarding the use of your personal information that we have as your Investment Advisor. Charter Oak (referred to as "we", "our" and "us" throughout this notice) protect the security and confidentiality of the personal information we have and make efforts to ensure that such information is used for proper business purposes in connection with the management or servicing of your account. Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything we can to maintain that trust.  

We do not sell your nonpublic personal information to anyone. Nor does Charter Oak provide such information to others except for discrete and proper business purposes in connection with the servicing and management of your account as discussed below.

Details of our approach to privacy and how your personal nonpublic information is collected and used are set forth in this privacy policy. 

The Information We Collect About You

You typically provide personal information when you complete the paperwork required to become our

Client. This information may include your:

• Name and address
• E-mail address
• Phone number
• Social security or taxpayer identification number
• Assets
• Income
• Investment activity
• Account balance
• Accounts at other institutions

In addition, we may collect nonpublic information about you from the following sources:

• Information we receive on Brokerage Agreements, Managed Account Agreements and other Subscription and Account Opening Documents;
• Information we receive in the course of establishing a customer relationship including, but not limited to, applications, forms, and questionnaires;
• Information about your transactions with us or others

Information about You That Charter Oak Shares

Charter Oak works to provide products and services that benefit our customers. We may share nonpublic personal information with non-affiliated third parties (such as brokers and custodians) as necessary for us to provide agreed services and products to you consistent with applicable law. We may also disclose nonpublic personal information to other financial institutions with whom we have joint business arrangements for proper business purposes in connection with the management or servicing of your account. In addition, your nonpublic personal information may also be disclosed to regulators in order to satisfy Charter Oak’s regulatory obligations; to resolve customer disputes or inquiries, with rating agencies, persons assessing compliance with industry standards; or to the attorneys, accountants and auditors of the firm; in connection with a sale or merger of the Advisor’s business; to protect against or prevent actual or potential fraud, identity theft, unauthorized transactions, claims or other liability; in any circumstances with the client’s instruction or consent and is otherwise required or permitted by law. Lastly, we may disclose your nonpublic personal information to companies we hire to help administrate our business. Companies we hire to provide services of this kind are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to the performance of the specific service we have requested.

To repeat, we do not sell your nonpublic personal information to anyone.  
 

Confidentiality and Security 

Our employees are advised about the firm's need to respect the confidentiality of our customers' nonpublic personal information. Additionally, we maintain physical, procedural and electronic safeguards in an effort to protect the information from access by unauthorized parties.

We'll keep you Informed

We will send you notice of our privacy policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise our privacy policy, and will provide you with a revised policy if the changes materially alter the previous privacy policy. We will not, however, revise our privacy policy to permit the sharing of nonpublic personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. You may obtain a copy of our current privacy policy by contacting us at (800) 646-5720.