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At Stembrook Asset Management, LLC (Stembrook), our most important asset is our relationship with our clients.  We are honored that you have entrusted us with your financial affairs, and we are committed to safeguarding the privacy of information we maintain about our clients.  Establishing and adhering to effective privacy principles is an important part of that dedication.

To affirm our continuing commitment to the proper use of client information, we have set forth the following Privacy Principles. 


  1. We do not and will not sell our client’s personal information, to anyone, for any reason, at any time.


  2. Use, Collection, and Retention of Client Information: Stembrook limits the use, collection, and retention of client information to what we believe is necessary or useful to conduct our business, and to provide quality service and advice to our clients. Information collected may include, but is not limited to: name, address, telephone number, tax identification number, date of birth, employment status, annual income and net worth.


  3. Maintenance of Accurate Information: Stembrook recognizes that it must maintain accurate client records. Therefore, Stembrook has established procedures to maintain the accuracy of client information and to keep such information current and complete. These procedures include responding to requests to correct inaccurate information in a timely manner.


  4. Limiting Employee Access to Information: At Stembrook, employee access to personally identifiable client information is limited to those with a business reason to know such information. Employees are educated on the importance of maintaining the confidentiality of client information and on these Privacy Principles. Because of the importance of these issues, all Stembrook employees are responsible for maintaining the confidentiality of client information and employees who violate these Privacy Principles will be subject to disciplinary measures.


  5. Protection of Information via Established Security Procedures: Stembrook recognizes that a fundamental element of maintaining effective client privacy procedures is to provide reasonable protection against the unauthorized access to client information. Therefore, Stembrook has established appropriate security standards and procedures to guard against any unauthorized access to client information.


  6. Restrictions on the Disclosure of Client Information: When it comes to sharing client information with unaffiliated companies, Stembrook places strict limits on who receives specific information about client accounts and other personally identifiable data. Stembrook may share information with such companies if they provide a product or service that may benefit our clients. Whenever we do this, we carefully review the company and the product or service to make sure that it provides value to our clients.

    We share the minimum amount of information necessary for that company to offer its product or service. We may also share information with unaffiliated companies that assist us in providing our services to our clients; in the normal course of our business (for example, with consumer reporting agencies and government agencies); when legally required or permitted in connection with fraud investigations and litigation; in connection with acquisitions and sales; and at the request or with the permission of a client.


  7. Maintaining Client Privacy in Business Relationships with Third Parties: If we provide personally identifiable client information to a third party with which we have a business relationship, we will insist that the third party keep such information confidential, consistent with the conduct of our business relationship.


  8. Disclosure of Privacy Principles to Clients: Stembrook recognizes and respects the privacy expectations of our clients. We want our clients to understand our commitment to privacy in our use of client information. As a result of our commitment, we have developed these Privacy Principles which are made readily available to our clients. Clients who have questions about these Privacy Principles or have a question about the privacy of their client information should call Peter D’Agati at 201-484-0063 or e-mail him at info@stembrook.com.

These Privacy Principles apply to individuals, and we reserve the right to change these Privacy Principles, and any of the policies or procedures described above, at any time without prior notice. These Privacy Principles are for general guidance and do not constitute a contract or create legal rights and do not modify or amend any agreements we have with our clients.
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