An important part of the relationship we have with our clients is the information you share with us. Protecting your privacy is important to us and we want you to know how we treat your nonpublic personal
information.
Pursuant to Title V of the Gramm-Leach-Bliley Act and United States Securities and Exchange Commission (“SEC”) Regulation S-P (17 CFR 248.1 – 248.30), this document explains the Privacy Policy of Devkota Capital Advisors LLC (“Devkota Capital Advisors LLC”) concerning the privacy interests of our clients. Devkota Capital Advisors LLC is a California Limited Liability Corporation with its office in Dublin California. Devkota Capital Advisors LLC is an investment adviser registered with the California Department of Business Oversight. Devkota Capital Advisors LLC’s principal business is to act as an investment adviser in accordance with all laws, rules and regulations applicable to investment advisers and the business conducted by investment advisers. As an investment adviser, Devkota Capital Advisors LLC’s principal business is to provide investment advisory and investment management services to clients.
The policy of Devkota Capital Advisors LLC is to protect the confidentiality, integrity and security of any nonpublic personal information of its clients and prospective clients, and to prevent unauthorized access to, or the use or disclosure of such information. In its capacity as an investment adviser, investment manager, and in conducting its advisory business, Devkota Capital Advisors LLC receives and/or comes into contact with certain nonpublic personal information concerning its current and/or former customers. Devkota Capital Advisors LLC receives and/or comes into contact with the nonpublic personal information only for purposes of conducting its business as described above. Any and all such nonpublic personal information is hereinafter referred to as “nonpublic personal information.” For convenience, “you” or “your” refers to any and all client(s) described above and “we,” “our” and “us” refers to Devkota Capital Advisors LLC throughout this document.
We are committed to safeguarding the use of your nonpublic personal information. We protect the security and confidentiality of the nonpublic personal information we have collected, and make efforts to ensure that such information is used for proper business purposes in connection with the management or servicing of your account. Our relationship with you is our most important asset. We understand that you have entrusted us with your nonpublic personal information, and we do everything we can to maintain that trust.
We do not sell your nonpublic personal information to anyone. Nor do we provide such information to others except for discrete and proper business purposes, in connection with the servicing and management of your account as discussed below.
Details of our approach to privacy and how your nonpublic personal information is collected and used are set forth in this Privacy Policy.
In conducting business as described above, Devkota Capital Advisors LLC collects (or may collect), for example, the following types of nonpublic personal information:
We disclose to affiliates and non-affiliated third parties nonpublic personal information only in connection with us providing investment management services or in respect of conducting our investment advisory business. Such disclosures include, among other things, information related to transactions, settlement, billing, payment, processing, clearing, transferring, reconciling, collection and tax reporting. Such disclosures may be provided to affiliates and non-affiliated third parties:
We will disclose nonpublic personal information about former clients of our investment advisory and investment management business only as permitted and/or required by law or legal process, or with the former client’s consent.
Federal law gives you the right to limit the sharing of your nonpublic personal information, when: (1) sharing is for affiliates’ everyday business purposes, (2) sharing with affiliates is done to use your information to market to you, and (3) sharing with non-affiliates is done to use your information to market to you. We do not share your information in any of these ways. State laws and individual companies may give you additional rights to limit sharing.
We are committed to implementing and maintaining commercially reasonable and appropriate measures to maintain your nonpublic personal information in a secure and confidential fashion. Our information security procedures include, but are not limited to, the following features:
We regularly review, revise and update our information security procedures to account for changes in technology.
Nonpublic personal information about you will be maintained during the time you are a client, and for the required time thereafter that such records are required to be maintained by federal and state securities laws. After this required period of record retention, all such information will be destroyed.
We will send you notice of our Privacy Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise our Privacy Policy, and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of nonpublic personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing.
Section 502(a) of the G-L-B Act generally prohibits a financial institution, directly or through its affiliates, from sharing nonpublic personal information with a non-affiliated third party unless the institution (i) provides the consumer with a notice of the institution’s privacy policies and practices, (ii) provides the consumer with a clear and conspicuous notice that the consumer’s nonpublic personal information may be disclosed to non-affiliated third parties, (iii) gives the consumer an opportunity to opt out of that disclosure, and (iv) informs the consumer how to opt out.
Clients cannot opt out of allowing Devkota Capital Advisors LLC to share their nonpublic personal information with non-affiliated third parties which are necessary to service their accounts such as Custodians, Third Party Administrators or certain software vendors. We do not share client information with any third parties that do not need the information in order to provide some type of service for your account.
Anyone may request a copy of our Privacy Policy or procedures by contacting Aalok Devkota either in writing at 2426 Vinton Avenue, Dublin, California 94568, or by phone at (402) 770-4165.
Devkota Capital Advisors LLC (“Devkota Capital Advisors LLC”) adopted this policy with recognition that protecting the privacy and security of the nonpublic personal information we obtain about our clients is an important responsibility. We also know that you expect us to service you in an accurate and efficient manner. To do so, we must collect and maintain certain nonpublic personal information about you. We want you to know what information we collect and how we use and safeguard that information.
We collect certain nonpublic personal information about you (such as your name, address, social security number, etc.) that you provide on applications or other forms as well as communications (electronic, telephone, written or in person) with you or your authorized representatives (such as your attorney, accountant, etc.). We also collect information about your brokerage accounts and transactions (such as purchases, sales, account balances, inquiries, etc.).
Devkota Capital Advisors LLC does not disclose the nonpublic personal information we collect about our clients to anyone except: (1) in furtherance of our business relationship with clients, and then only to those persons necessary to effect the transactions and provide the services that clients authorize (such as broker-dealers, custodians, independent managers etc.); (2) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, etc.); (3) our attorneys, accountants, and auditors; or (4) as otherwise provided by law.
We are permitted by law to disclose the nonpublic personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative services on our behalf). These third parties are prohibited to use or share the information for any other purpose. If you decide to either terminate our services or become an inactive client, we will continue to adhere to our Privacy Policy, as may be amended from time to time.
We restrict access to your nonpublic personal information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your nonpublic personal information.
Our policy about obtaining and disclosing information may change from time to time. We will provide you notice of any material change to this policy before we implement the change.
Clients cannot opt out of allowing Devkota Capital Advisors LLC to share their nonpublic personal information with non-affiliated third parties which are necessary to service their accounts.
For a copy of our Privacy Policy, please contact the Chief Compliance Officer either in writing at 2426 Vinton Avenue, Dublin, California 94568, or by phone at (402) 770-4165.
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