The Franklin Square Capital Partners family of companies (“we” or “Franklin Square”) 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
We collect 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 Franklin Square investment products and services you purchase, your Franklin Square account balance or transactional history, the fact that you are or have been an investor in a Franklin Square sponsored investment and particulars related to any such investment. Specific examples of personal information that we may collect and may disclose to affiliates and certain third parties include:
How We Use and Disclose Information
The Franklin Square network of affiliated companies 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. We believe that by sharing information about you and your accounts among our companies and partners, we are 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 we collect is crucial to our ability to provide our clients with the type of goods and services they expect, and may occur under a variety of different circumstances. For example, we may:
Sharing Among Franklin Square Affiliates and Nonaffiliated Service Providers
We may share your personally identifiable information among Franklin Square 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
We 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 we collect to such parties. However, before we disclose 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, we 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. We may also disclose the following information to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements:
We require all joint marketers to have written contracts with us that specify appropriate use of your personal information, require them to take steps to safeguard your personal information, and prohibit them from making unauthorized or unlawful use of your personal information. Franklin Square does not share, sell, or rent your personal private information with outside marketers who may want to offer you their own products and services to you.
How We Protect Your Information
Franklin Square maintains a comprehensive information security program designed to ensure the security and confidentiality of customer information, protect against threats or hazards to the security of such information, and prevent unauthorized access. This program includes:
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