Privacy Policy

March 2023

Appendix B: Privacy Policy

What does SpiderRock Advisors, LLC (“SpiderRock Advisors”) do with your Personal Information?

Investment advisory firms collect certain personal information from individuals and choose how they share this personal information. Applicable law gives you as our client the right to limit some but not all information sharing. Applicable law also requires us to tell you how we collect, share, and protect your personal information or the personal information of your clients. Please read this notice carefully to understand what we do. 

We do not disclose nonpublic personal information about our clients or former clients to third parties, other than as described below. 

Personal information we collect

We collect personal information about you in connection with our providing advisory services to you. This information may include your name, address and social security number and may include other information such as your or your clients: 

• Net worth, assets and income

• Investment experience 
• Transaction history

How we collect this information 

We collect this information from you through various means. For example, this can occur when you give us your contact information, or enter into an advisory or sub-advisory contract with us. We also may collect your personal information from other sources, such as our affiliates or other non-affiliated companies (e.g., your custodian). 

Our affiliates are companies related to us by common ownership or control and can include both financial and nonfinancial companies. Non-affiliates are companies not related to us by common ownership or control and can include both financial and nonfinancial companies.

How we use this information

All financial companies need to share customers’ personal information to run their everyday business and we use the personal information we collect from you for our everyday business purposes. These purposes may include for example: 

• To provide advisory services to you 
• To open an account for you
• To process a transaction for your account
• To market products and services to you
• To respond to court orders and legal investigations 

Disclosure to others

We may disclose all of the information described above to certain third parties who are not affiliated with us under one or more of the following circumstances:

• As Authorized – if you request or authorize disclosure of the information.
• As Required by Law – for example, to cooperate with regulators or law enforcement authorities.
• As Otherwise Permitted by Law – to organizations with which we are not affiliated, if doing so is necessary to provide the service the client is buying (“Service Providers”) – for example, sharing information with companies that maintain, process or service client accounts or financial products and services or effect, administer or enforce client transactions is permitted. Among other activities, we may share information with broker-dealers in order to execute client trades or with custodians that hold securities on behalf of clients. We may also share your personal information with organizations who provide services to us, including lawyers, auditors, accountants, brokers, AML service providers, tax information exchange service providers, or other back office service providers. We believe that sharing of information for these purposes is essential to providing clients with necessary or useful services with respect to their accounts. 

These sharing practices are consistent with applicable privacy laws, and in general, you may not limit our use of your personal information for these purposes under such laws. We note that applicable privacy laws only give you the right to opt out of or otherwise limit certain types of information sharing that we do not engage in (e.g., sharing with our affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with non-affiliates for them to market to you). 

How we protect your personal information

We restrict access to information about you to those employees who need to know the information to service your account. Our employees are trained to follow our procedures to protect your privacy and are instructed to access information about you only when they have a business reason to obtain it. We use physical, electronic and procedural safeguards to keep your information secure. These protections and processes are further developed in the firm’s Cybersecurity Policies and Procedures.  

In situations where a financial institution does disclose client information to nonaffiliated third parties, other than permitted or required by law, clients must be given the opportunity to opt out or prevent such disclosure. As described herein, we do not share or disclose current, prospective and/or former clients’ nonpublic, personal information to nonaffiliated third parties except where permitted or required by law. Should we determine to change its privacy policy to permit disclosure of non-public information not covered under applicable law, we will allow our clients the opportunity to opt out of such disclosure.

Who to contact with questions  

If you have any questions concerning this privacy policy, please contact SpiderRock Advisors Compliance at (312) 847-0300 or at Compliance@spiderrockadvisors.com