DELPHI PRIVATE ADVISORS, LLC
Delphi Private Advisors (“Delphi”) maintains physical, electronic and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”). Through this policy and its underlying procedures, Delphi attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.
It is the policy of Delphi to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/non-affiliated entities who need to know that information in order to provide products or services in furtherance of the client’s engagement of Delphi. In that regard, Delphi may disclose the client’s information: (1) to individuals and/or entities not affiliated with Delphi, including, but not limited to, the client’s other professional advisors and/or certain service providers that may be recommended or engaged by Delphi in furtherance of the client’s engagement of Delphi (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, record keeper, etc.); (2) as required to do so by judicial or regulatory process; or (3) as otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. The disclosure of information contained in any documents completed by the client for processing and/or transmittal by Delphi to facilitate the commencement/continuation/termination of a business relationship between the client and Delphi and/or between Delphi and a non-affiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, record keeper, insurance company, etc.), including, but not limited to, information contained in any documents completed and/or executed by the client in furtherance of the client’s engagement of Delphi (i.e., advisory agreement, client information form, custodial account applications, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding non-affiliated third party service provider.
Should you have any questions regarding the above, please contact Gary Hirschfeld, Delphi’s Chief Compliance Officer.