Privacy Policy
As a registered investment adviser, Henry James International Management℠ must comply with SEC Regulation S-P (or other applicable regulations), which requires registered advisers to adopt policies and procedures to protect the “nonpublic personal information” of its clients and to disclose to such persons policies and procedures for protecting that information. Nonpublic personal information includes nonpublic “personally identifiable financial information” plus any list, description, or grouping of customers that is derived from nonpublic, personally identifiable financial information. Such information may include personal financial and account information, information relating to services performed for or transactions entered into on behalf of clients, advice provided by Henry James to clients, and data or analyses derived from such nonpublic personal information.
The purpose of these privacy policies and procedures is to provide administrative, technical, and physical safeguards that assist employees in maintaining the confidentiality of nonpublic personal information collected from the client of an investment adviser. All nonpublic information, whether relating to an adviser’s current or former clients, is subject to these privacy policies and procedures. Any doubts about the confidentiality of client information must be resolved in favor of confidentiality.
Henry James International Management℠ has adopted various procedures to implement the firm’s policy and reviews to monitor and ensure the firm’s policy is observed, implemented properly, and amended or updated, as appropriate, which include the following:
Non-Disclosure of Client Information: Henry James maintains safeguards to comply with federal and state standards to guard each client’s nonpublic personal information. Henry James does not share any nonpublic personal information with any nonaffiliated third parties, except in the following circumstances:
As necessary to provide the service that the client has requested or authorized or to maintain and service the client’s account;
As required by regulatory authorities or law enforcement officials who have jurisdiction over Henry James International Management℠ or as otherwise required by any applicable law; and
To the extent reasonably necessary to prevent fraud and unauthorized transactions.
Upon a client’s written request to third-party service providers, such as accountants and lawyers, or family members.
Security of Client Information: Henry James restricts access to nonpublic personal information to those employees who need to know such information to provide services to our clients.
Privacy Notices: Henry James International Management℠ will provide each natural person client with initial notice of the firm’s current privacy policy when the client relationship is established. If, at any time, Henry James International Management℠ adopts material changes to its privacy policy, the firm shall provide each client with a revised notice reflecting the new privacy policy.