Privacy & Confidentiality Policy
Our commitment to protecting your personal and financial information
Effective Date: March 28, 2023
Last Updated: January 2025
Introduction
Buckhead Capital Management, LLC ("Buckhead Capital," "we," "our," or "us") is committed to maintaining the confidentiality, integrity, and security of personal information entrusted to us by our clients. This Privacy and Confidentiality Policy explains how we collect, use, disclose, and protect your personal and financial information in accordance with federal and state privacy laws and regulations.
Our Commitment: As a registered investment adviser and fiduciary, protecting your privacy is a fundamental aspect of our professional responsibility and client service commitment.
Information We Collect
Personal Information
To provide investment management and advisory services, we collect various types of personal information, including:
- Identity Information: Name, date of birth, Social Security number, government-issued identification numbers, and similar personal identifiers
- Contact Information: Address, telephone numbers, email addresses, and preferred communication methods
- Financial Information: Income, net worth, assets and liabilities, investment experience, risk tolerance, financial goals, and investment objectives
- Account Information: Account numbers, transaction history, holdings, performance data, and custodian information
- Employment Information: Employer name, occupation, employment status, and professional affiliations
- Family Information: Marital status, dependents, beneficiary information, and related family financial matters
Information from Other Sources
We may also receive information about you from third parties, including:
- Account custodians and financial institutions
- Other financial advisors or professionals you authorize to share information with us
- Credit bureaus and verification services (with your authorization)
- Public records and databases
Website and Technology Information
When you visit our website or use our technology platforms, we may automatically collect certain technical information, including IP addresses, browser type, device information, usage patterns, and cookies or similar tracking technologies. This information helps us improve our services and user experience.
How We Use Your Information
We use the information we collect for legitimate business purposes related to providing investment management and advisory services:
Service Delivery
- • Managing investment accounts
- • Providing financial advice
- • Executing transactions
- • Monitoring portfolio performance
Compliance & Legal
- • Complying with legal obligations
- • Meeting regulatory requirements
- • Preventing fraud and abuse
- • Maintaining required records
Client Communication
- • Responding to inquiries
- • Providing account updates
- • Sending relevant communications
- • Delivering reports and statements
Business Operations
- • Improving our services
- • Conducting research and analysis
- • Managing business operations
- • Training staff members
Information Sharing and Disclosure
Limited Disclosure
We do not sell, rent, or trade your personal information to third parties for marketing purposes. We may share your information only in the following limited circumstances:
- Service Providers: We may share information with third-party service providers who assist us in delivering services, such as custodians, technology providers, compliance consultants, and professional advisors, under strict confidentiality agreements.
- Legal Requirements: We may disclose information when required by law, regulation, legal process, or governmental request, including responding to subpoenas, court orders, or regulatory inquiries.
- With Your Consent: We may share information with other parties when you have provided explicit authorization or consent for such disclosure.
- Business Transfers: In the event of a merger, acquisition, or sale of assets, client information may be transferred to the successor entity, with continued protection under applicable privacy laws.
Former Clients
We maintain the same privacy protections for former clients as we do for current clients. Information about former clients is retained and protected in accordance with our record retention policies and applicable legal requirements.
Information Security
We maintain physical, electronic, and procedural safeguards designed to protect your personal information from unauthorized access, use, or disclosure:
Physical Security
Secure office facilities with restricted access and document storage protocols
Electronic Security
Encryption, firewalls, secure servers, and password-protected systems
Procedural Security
Employee training, confidentiality agreements, and access controls
Security Notice: While we implement robust security measures, no system can guarantee absolute security. We continuously monitor and update our security practices to address evolving threats and maintain the highest standards of information protection.
Your Privacy Rights
Access and Correction
You have the right to review and request corrections to your personal information maintained in our records. To exercise this right, please contact us using the information provided below.
Opt-Out Rights
While we do not share information for marketing purposes, you may opt out of certain types of communication:
- Marketing emails and newsletters (account-related communications will continue)
- Promotional telephone calls
- Physical mailings for marketing purposes
State-Specific Rights
Residents of certain states may have additional privacy rights under state law, including rights to access, delete, or restrict the use of personal information. Please contact us to learn more about rights that may be available to you.
Data Retention
We retain personal information for as long as necessary to fulfill the purposes outlined in this policy, comply with legal and regulatory requirements, resolve disputes, and enforce our agreements. Investment adviser records are generally retained for at least five years following account closure, as required by SEC regulations.
Third-Party Websites
Our website may contain links to third-party websites or services. This Privacy Policy does not apply to those third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.
Children's Privacy
Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected information from a child, we will take steps to delete such information.
Policy Updates
We may update this Privacy and Confidentiality Policy periodically to reflect changes in our practices, technologies, legal requirements, or other factors. We will notify clients of material changes through written notice or prominent posting on our website. Your continued use of our services after such notice constitutes acceptance of the updated policy.
Contact Us
If you have questions about this Privacy and Confidentiality Policy, wish to exercise your privacy rights, or have concerns about how your information is handled, please contact us:
Buckhead Capital Management, LLC
Atlanta, GA 30339
NAICS: 523900 - Other Financial Investment Activities
Your privacy matters to us. We are committed to maintaining the trust you place in us by protecting your personal and financial information with the highest standards of confidentiality and security.