Our Commitment to You
Important Disclosure Document: Form CRS
Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Graham (also referred to as “we”, “our” and “us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you.
Graham does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of yo the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information.
What information do we collect from you?
|Driver’s license number||Date of birth|
|Social security or taxpayer identification number||Assets and liabilities|
|Name, address and phone number(s)||Income and expenses|
|E-mail address(es)||Investment activity|
|Account information (including other institutions)||Investment experience and goals|
What Information do we collect from other sources?
|Custody, brokerage and advisory agreements||Account applications and forms|
|Other advisory agreements and legal documents||Investment questionnaires and suitability documents|
|Transactional information with us or others||Other information needed to service account|
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information.
We require third protect the personal information they receive from us.