Blue Elephant Capital Management, LLC (“Blue Elephant” or the “Firm”) takes measures to ensure that the use and disclosure of your private personal information is consistent with applicable law.
Information That We Collect and May Disclose
Blue Elephant collects information from and about you in order to provide the superior level of service that you expect. Nonpublic personal information about you may include: your name, mailing address, e-mail address, tax identification number, age, account information, investment amounts in our companies, marital status, number of dependents, assets, debts, income, net worth, employment history, financial statements, beneficiary information, personal bank account information, credit history information, broker dealer, financial advisor, IRA custodian, account joint owners and other similar parties, the Firm’s investment products and services you purchase, your account balance or transactional history with the Firm, the fact that you are or have been an investor in a Firm sponsored investment and particulars related to any such investment.
Specific examples of personal information that the Firm may collect and may disclose to affiliates and certain third parties include:
- Information the Firm receives from you on applications, subscription agreements, or other forms. Examples include your name, mailing address, and e-mail address.
- Information about your transactions with the Firm, its affiliates, and others such as account balances, payment history, account activity and financial statements.
- If you visit the Firm’s Internet website, www. bluelep.com.
- If you create a login and password on one of the websites to access your account with the Firm, Blue Elephant will collect and use the login and password to verify your identity and for the Firm’s internal use in maintaining your website account.
- Information obtained from others, such as credit reports from consumer credit reporting agencies.
How We Use and Disclose Information
Blue Elephant and third-party service providers work together to provide a variety of investment products and services, and they may need to share some or all nonpublic personal information collected on you to maintain an efficient and effective network of products and services. Blue Elephant believes that by sharing information about you and your accounts among our companies and partners, the Firm is better able to serve your investment needs and to suggest services or educational materials that may be of interest to you. The responsible use and disclosure of the nonpublic personal information the Firm collects is crucial to our ability to provide our clients with the type of products and services they expect, and may occur under a variety of different circumstances. For example, the Firm may:
- Use your personally identifiable information internally for the purposes of analyzing our business, which may include analyzing your information, matching your information with the information of others, processing services, maintaining accounts, resolving disputes, preventing fraud and verifying your identity.
- Disclose your personally identifiable information when required by law, such as requests for personal information in connection with a judicial, administrative or investigative matter.
Sharing Amongst Blue Elephant Affiliates and Nonaffiliated Service Providers
Blue Elephant may share your personally identifiable information among Firm affiliates engaged in investment or other related financial service activities. Examples might include customer-initiated service requests, establishing and managing your investor accounts, completing your investor transactions, and sharing information with parties acting at your request and on your behalf, such as your broker-dealer, financial advisor, joint owners and IRA custodian.
Sharing With Nonaffiliated Service Providers
Blue Elephant may disclose your personal information to nonaffiliated service providers who perform business functions on our behalf, which may include marketing of our own investment products and services, check printing, and data processing. Nonaffiliated third party service providers often aid us in the efficient and effective delivery of services and there may be circumstances where it is necessary to disclose nonpublic personal information the Firm collects to such parties. However, before the Firm discloses nonpublic personal information to a nonaffiliated party, we require them to agree to keep our investor information confidential and secure and to use it only as authorized by us. Also, Blue Elephant will only share your nonpublic information with nonaffiliated third parties under circumstances not covered by state or federal law “opt-out” notice exceptions, such as servicing a financial product or service authorized by the customer, resolving consumer disputes, and protecting against potential fraud or unauthorized transactions. Should this policy ever change in the future, you will be given adequate notice and the option to “opt-out” of such disclosure.
How the Firm Protects Your Information
Blue Elephant maintains a comprehensive information security program designed to ensure the security and confidentiality of customer information, protects against threats or hazards to the security of such information, and prevents 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 to 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.
Change in Control
- A reorganization, merger, consolidation, acquisition or other restructuring involving all or substantially all of Blue Elephant’s voting securities and/or assets, by operation of law or otherwise.
- A general assignment for the benefit of creditors.
- The appointment of a receiver.
- The filing of a bankruptcy or insolvency proceeding.
- The liquidation of assets.