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Privacy Policy:

Effective November 13, 2000 the SEC adopted Regulation S-P covering Privacy of Customer Financial Information. Regulation S-P requires that Tarheel Advisors, LLC adopt and maintain written supervisory procedures that comply with Regulation S-P and serve to protect the privacy of customer data.

Regulation S-P requires that Tarheel Advisors, LLC provide each client with a Privacy Notice. In addition, where Tarheel Advisors, LLC discloses “nonpublic personal information” about clients outside of certain permitted exceptions (chiefly related to the needs of the business) Tarheel Advisors, LLC must obtain the client’s permission.

1. Who Is Protected?

The regulation protects only individuals; thus, trusts, partnerships, and corporations are not protected. Beneficiaries of trusts, 401(k) participants, shareholders of corporations or partners of partnerships are not protected. IRA beneficiaries are protected since they are individuals. Institutional investors are not covered by the regulation and no disclosures are required to be made to institutional customers or consumers. The Regulation protects “Consumers” and “Customers.” A “Consumer” gets Notice protection if Tarheel Advisors, LLC starts to disclose that Consumer’s “Nonpublic Personal Information” (NPI) to a “non-affiliated third parties” (NTP). A “Customer” always gets Notice protection.

It is the policy of Tarheel Advisors, LLC to not disclose or sell personal information of any of our clients to third parties, unless:

·         You have requested that we share this information with one of your other professional advisors, e.g., attorney, accountant.

·         We believe in good faith that the disclosure is required or permitted under law, e.g., to cooperate with regulators, perform credit/authentication checks.

·         Disclosing information is part of regular business, e.g. opening a brokerage account.

2. What Is Protected?

With certain exceptions set forth below, Tarheel Advisors, LLC is required to protect “Nonpublic Personal Information.”  

Regulation S-P specifically requires the Privacy Notice to state that Tarheel Advisors, LLC may disclose NPI about former Customers as well as current ones. The Regulation does not require that a Privacy Notice be provided to any former Customer.

TARHEEL ADVISORS, LLC AS A POLICY DOES NOT DISCLOSE ANY CONSUMER OR CUSTOMER NON-PUBLIC INFORMATION TO NON-RELATED THIRD PARTIES OTHER THAN IN CONTROLLED CIRCUMSTANCES AS SPECIFICALLY ALLOWED BY REGULATION S-P.

3. How Is It Protected?

We protect the confidentiality and security of your personal information.

·         We restrict access to personal information to our employees for business purposes only. All employees are trained and required to safeguard such information.

·         We maintain physical, electronic and procedural safeguards to guard your personal information.

4. Notice Requirements

The Regulation requires Tarheel Advisors, LLC to provide an Initial Privacy Notice to (a) every Customer at all times and (b) every Consumer where Tarheel Advisors, LLC intends to disclose that Consumer’s NPI to any NTP under any non-exempt circumstances. Each recipient must also have been provided with a “reasonable” time to “opt out” or not.

The Initial Privacy Notice must be provided to the Customer, with certain exceptions, AT OR BEFORE the time Tarheel Advisors, LLC establishes the Customer relationship and to the Consumer BEFORE Tarheel Advisors, LLC makes any disclosures of that Consumer’s NPI to a NTP. The Initial Privacy Notice may be provided in written or electronic form (if the Consumer or Customer is able to acknowledge receipt electronically). The exceptions are as follows: The Initial Privacy Notice may be provided at a “reasonable” later time where (a) the Customer relationship has been established without the Customer’s knowledge or consent; (b) where to provide the Notice would substantially delay the Customer’s transaction and the Customer has agreed to receive the Notice at a later date; or (c) where the NTP establishes an account or purchases securities on behalf of the Customer.

Tarheel Advisors, LLC’s Privacy Notice must be sent in writing to each Customer at least once every 12 months, giving that Customer an opportunity to “opt out” within a reasonable time of receiving the Notice. The Annual Privacy Notice may be delivered over Tarheel Advisors, LLC’s website if the Customer agrees in advance.

5. Books and Records Requirement

We constantly evaluate our information accuracy and protection.

·         Please contact us if you see any inaccuracy in your personal information or you need to make a change in your information.

6. Superseding Authorities

Regulation S-P does not supersede, alter or affect any state law or regulation which provides protection which is greater than that created by Regulation S-P. Accordingly, Tarheel Advisors, LLC should be aware of comparable provisions in states where it is doing business. Similarly, Regulation S-P does not modify, limit or supersede the Fair Credit Reporting Act (15 U.S.C. 1681), particularly Section 603 that allows companies to provide selected credit information to lenders.