Eagle Ridge Investment Management, LLC
Regulation S-P (“Reg S-P”) requires registered investment advisers to adopt and implement policies and procedures that are reasonably designed to protect the confidentiality of nonpublic personal records. The firm is committed to protecting the confidentiality of all information of all clients and prospective clients.
The Firm will provide clients with prompt notice of any significant changes to the Company’s privacy policies, and will give clients sufficient opportunity to opt out of any new disclosure provisions.
Although these procedures apply specifically to Nonpublic Personal Information, employees must be careful to protect all of the firm’s proprietary information.
Personal Information Collected
Eagle Ridge collects personal information about its clients to evaluate their financial needs, manage their accounts, and provide individualized investment advice. The personal information obtained includes:
information provided on applications and other forms (such as name, contact information social security number, occupation, assets, and income) and any additional information communicated to the company which impacts clients’ financial circumstances;
information about clients’ assets and transactions such as custodial statements and trade confirmations;
information obtained from clients in connection with providing financial services such as correspondence, emails and notes from telephone conversations or meetings.
Personal Information Protection
Employees are required to maintain the confidentiality of information acquired in connection with their employment, with particular care being taken regarding nonpublic personal information. Improper use of the Firm’s proprietary information, including personal information, is cause for disciplinary action, up to and including termination of employment for cause and referral to appropriate civil and criminal legal authorities. Nonpublic Personal Information is restricted to employees who have a need to know such information. To comply with applicable laws and regulations, Eagle Ridge maintains physical, electronic, and procedural safeguards to protect this information. Eagle Ridge also employs technology consultants who help maintain the firm’s network and software systems.
Personal Information Disclosure
Eagle Ridge may share the personal information described above for business purposes with the following companies not affiliated with us:
Financial Service Providers – such as banks and brokers that provide custody and trade execution necessary to manage clients’ portfolios;
Professionals – such as accountants, lawyers, actuaries and trust officers who may be involved in providing ancillary financial services provided clients request or consent to the dissemination of this information;
Data Service Providers – such as third party technology consultants;
Portfolio Management Systems and Planning Software Providers;
Regulatory Authorities – as required by law;
Others – as directed by the client.
Outside Business Activity
All personnel of Eagle Ridge must notify the firm and file an Outside Business Activity form before engaging in any business activity unrelated to Eagle Ridge. The form is available in Appendix IX of the Compliance Manual.