Protecting the privacy and security of our clients’ confidential information is important to us. This notice describes the practices and policies through which we maintain the confidentiality and protect the security of your non-public personal information.
What Information We Collect
While providing services to you we may collect the following types of “non-public personal information” about you:
- Information we receive from you or your agents on applications or other forms or statements, or by electronic means or telephone, such as your name, address, social security number, assets, income, types and amounts of investments and other financial, brokerage and bank account information, and
- Information about your transactions with us our affiliates and others, as well as other account data. We may also receive information from other firms, such as those from which you transfer assets to your current custodian or to which you subsequently transfer assets.
“Non-public personal information” is non-public information about you that we obtain in connection with providing a service to you, such as the information described in the above examples.
“Affiliates” include companies related to Vogel Consulting, LLC through common control or ownership. For this purpose, Vogel Consulting Group, S.C. is considered our affiliate.
What Information We Disclose
We do not disclose non-public personal information about you to non-affiliated third parties, except as permitted or required by law. We do not sell any personal information about our clients to third parties. We are permitted by law to share any of the information we collect, as described above, with our affiliates and we may share that information with our affiliates. In addition, in the normal course of serving clients, information we collect may be shared with companies that perform various services for you such as other advisors you have an affiliation with including your attorneys, transfer agents, auditors, custodians and broker-dealers. These companies are to use this information only for the services for which you hired them and as allowed by applicable law.
Confidentiality and Security Procedures
To protect your personal information, we permit access only by authorized employees. We maintain physical, electronic and procedural safeguards to protect the confidentiality, integrity and security of your non-public personal information. Our employees are instructed to keep clients’ personal and financial information confidential and not to disclose it to unauthorized persons, either during their employment with Vogel or afterward. We do not collect non-public personal information about our clients on our website but may through our internet portal.
We will continue to adhere to the privacy policies and practices in this notice even after your account is closed or becomes inactive.
Transfer to US or other Countries
Your information may be stored and processed in the United States or any other country where Vogel has facilities, and by using our services, you consent to the transfer of information outside of your country.
Notice of Availability of Form ADV
As part of Vogel’s requirements under applicable state and/or federal law, Vogel at least annually offers to deliver to its clients a current copy of our Form ADV, Part II, or equivalent brochure free of charge if you request a copy. If you want a copy of this document in response to this offer, please contact your Family Office Director.
Client Notification of Status Changes
In order to advise you in making investment decisions about your account according to your investment objectives and risk tolerance, it is incumbent on you to inform your account financial advisor of any changes to your financial status, financial objectives, risk tolerance, investment time horizon or policies and restrictions that may affect investment decisions. Please notify your account financial advisor in writing of any changes to the information previously provided.