Registered Investment Adviser

Commitment to Privacy

Carissima Capital LLC (“Carissima”) does not sell or make available to non-affiliated third parties non-public information obtained by Carissima from a client (“Client Information”) without the prior consent of the client, except as set forth below in this Privacy Policy.

How Carissima Gathers Information

In connection with Carissima providing services to a client, Carissima may obtain information about the client, including Client Information, from sources, such as the following:

• Client agreements and other information that the client provides to Carissima, whether in writing, in person, by telephone, electronically or by any other means. This information may include the client’s name, address, phone number, email address, social security number, employment information, income, investment experience, and credit information.
• Personal tax returns provided to Carissima by the client.
• Transactions on a client’s behalf. This information may include the client’s account balances, positions, investments, and history.
• Public sources.

Sharing Information with Nonaffiliated Third Parties

Carissima only discloses Client Information to nonaffiliated third parties without prior client consent when Carissima believes it necessary for the conduct of our business or as required or permitted by law, such as the following:

• If requested or authorized by the client;
• To provide client account services or account maintenance;
• To respond to a subpoena or court order, judicial process, law enforcement or regulatory authorities;
• To perform services for Carissima or on its behalf to develop or maintain transaction or operational capability through software, technology or otherwise;
• In connection with a proposed or actual sale, merger, or transfer of all or a portion of our business;
• To help Carissima prevent fraud;
• To rating agencies, persons assessing compliance with industry standards, or to the attorneys, accountants and/or auditors of Carissima; or
• To comply with federal, state or local laws, rules and other applicable legal requirements.

Carissima does not disclose Client Information to other companies that wish to sell products or services to you. For example, we do not sell client lists, and we will not sell client names to catalog companies.

Opt Out Provision

If, at any time, Carissima believes that it is necessary to disclose any Client Information of a client in a way that is inconsistent with this Privacy Policy, Carissima will give the client advance notice of the proposed disclosure so that the client will have the opportunity to either opt-in or opt-out of such disclosure, subject to and in accordance with applicable law. Clients desiring to opt out of disclosure of Client Information to a third party should contact Carissima immediately. 

To Whom This Policy Applies

This Privacy Policy applies to each client who is receiving services from Carissima under a written agreement with Carissima. In addition, this Privacy Policy applies to all former clients.

Security Practices and Information Accuracy

Carissima takes steps to safeguard Client Information. Carissima restricts access to the personal and account information of our clients to our employees and agents for business purposes only. We maintain physical, electronic and procedural safeguards to guard Client Information. Additionally, we have internal controls to keep Client Information as accurate and complete as we can. If you believe that any Client Information about you is not accurate, please let us know.

Changes

Carissima reserves the right to change this Privacy Policy at any time and will provide notice of each such change in accordance with applicable law.