Privacy Policy: Protection of Client Financial Information

Policy

As a registered investment adviser, Harmony Asset Management LLC 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 natural person consumers and customers 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 Harmony Asset Management LLC to clients, and data or analyses derived from such nonpublic personal information.

Harmony Asset Management LLC must also comply with the California Financial Information Privacy Act (SB1) if the firm does business with California consumers.

Harmony Asset Management LLC does not disclose any confidential personal information about our customers or former customers without prior authorization from customers, except as required by law or in response to inquiries from governmental authorities. We may disclose such information to unaffiliated third parties such as brokers or custodians only as permitted by law and only as needed for us to provide agreed upon services to customers.

Background

The purpose of these privacy policies and procedures is to provide administrative, technical and physical safeguards which assist employees in maintaining the confidentiality of nonpublic personal information collected from the consumers and customers 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.

Harmony Asset Management LLC collects nonpublic financial information from the following sources:

  1. Information we receive from clients on application and other forms;
  2. Information about client transactions with us, our affiliates, or others, and;
  3. Information derived during the course of consultations regarding management of client accounts.

Responsibility

The Chief Compliance Officer is responsible for reviewing, maintaining and enforcing these policies and procedures to ensure meeting Harmony Asset Management LLC’s client privacy goals and objectives while at a minimum ensuring compliance with applicable federal and state laws and regulations.

Procedure

Harmony Asset Management LLC has adopted various procedures to implement the firm’s policy and reviews to monitor and insure the firm’s policy is observed, implemented properly and amended or updated, as appropriate, which include the following:

Non-Disclosure of Client Information

Harmony Asset Management LLC maintains safeguards to comply with federal and state standards to guard each client’s nonpublic personal information.

Harmony Asset Management LLC does not share any nonpublic personal information with any nonaffiliated third parties, except in the following circumstances::

  1. As necessary to provide the service that the client has requested or authorized, or to maintain and service the client’s account;
  2. As required by regulatory authorities or law enforcement officials who have jurisdiction over Harmony Asset Management LLC, or as otherwise required by any applicable law; and
  3. To the extent reasonably necessary to prevent fraud and unauthorized transactions. Employees are prohibited, either during or after termination of their employment, from disclosing nonpublic personal information to any person or entity outside Harmony Asset Management LLC, including family members, except under the circumstances described above. An employee is permitted to disclose nonpublic personal information only to such other employees who need to have access to such information to deliver our services to the client.

Exception for Representatives Who Move to a New Firm

Harmony Asset Management employees who have an established business relationship with a specific client rather than a general client affiliation with the firm may, under specific limited circumstances, disclose protected information to the new firm. That information is strictly limited to:

Customer’s name:
General description of the types of accounts held;
General description of the type of products held; and
Address, telephone number and e-mail contact information.

The information must not include a social security number, account numbers, specific securities positions or financial data of any kind.

Representatives, prior to departing must provide the CCO a written record of the information they intend to provide their new employer, (or intend to use in their own investment business) and receive written approval of each item. Failure to follow these requirements will provide the basis for legal action.

Security of Client Information

Harmony Asset Management LLC restricts access to nonpublic personal information to those employees who need to know such information to provide services to our clients.

To the extent possible nonpublic client information is maintained in secure, code accessed, electronic format.

Paper copies of nonpublic client information that are no longer needed are disposed of through the use of a secure shredder under the personal supervision of the CCO.

Privacy Notices

Harmony Asset Management LLC will provide each natural person client with initial notice of the firm’s current policy when a client relationship is established. Harmony Asset Management LLC shall also provide each such client with a new notice of the firm’s current privacy policies at least annually. If Harmony Asset Management LLC shares nonpublic personal information relating to a California consumer with an affiliated company under circumstances not covered by an exception under SB1, the firm will deliver to each affected consumer an opportunity to opt out of such information sharing. If, at any time, Harmony Asset Management LLC adopts material changes to its privacy policies, the firm shall provide each such client with a revised notice reflecting the new privacy policies. The Chief Compliance Officer is responsible for ensuring that required notices are distributed to Harmony Asset Management LLC’s consumers and customers.

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