Website Privacy Notice

GEM Asset Management, LLC respects your right to privacy. In order for us to conduct our business in compliance with applicable laws and in an accurate and efficient manner, we must collect and maintain certain personal non-public information about you, our client. The categories of nonpublic personal information that we collect from each client depends upon the scope of the client engagement. We collect nonpublic personal information about you from the following sources:

• Information we receive from you on applications or on other forms, such as your name, address, social security number, financial information, and information about investment goals and risk tolerance.
• Information about your transactions with us, custodians, or others, such as your capital account balances, investment cost, investment distributions, and investment gain or loss.

“Nonpublic personal information” is nonpublic information about you that we obtain in connection with providing a financial service to you for personal, family or household purposes. It does not include information available from government records, widely distributed media, or government mandated disclosures.

We do not disclose nonpublic personal information about our clients or former clients to anyone except as otherwise permitted by law. For example, we are permitted by law to share information about you with:

• Companies that assist us in processing your transactions and servicing your account.
• A brokerage firm in order to execute securities transactions on your behalf.
• Your accountant, lawyer, spouse or other family members, or other advisors, with your consent.
• Companies that perform services on our behalf, such as legal counsel.
• Governmental regulatory bodies that request the information from us (for example, to verify the availability of exemptions from registration).

We do not provide your nonpublic personal information to direct marketers or solicitors for any purpose.

If you decide to close your account(s), we will continue to adhere to the privacy practices described in this notice when you before a former client. You become a former client when your client services agreement with us is terminated.  We will maintain nonpublic personal information about you during the time you are a client, and for any time thereafter that we are required to maintain the records by federal or state securities laws. After this required period of record retention, we generally destroy your information.

We take all reasonable steps to assure the privacy of client information. We restrict access to nonpublic personal information about you to those employees who have a business or professional reason for knowing, as permitted by laws. We maintain a secure office and computer environment to ensure that your personal information is not placed at unreasonable risk. We maintain physical, electronic and procedural safeguards to guard your nonpublic personal information.

If at any time you have any questions about our privacy policy or practices, please do not hesitate to contact Steve Alexandrowski at 734-737-9108.