Privacy Policy

Background

As a registered investment adviser, Fisher Investments (FI) must comply with SEC Regulation S-P, which requires registered advisers to adopt policies and procedures to protect the “nonpublic personal information” of natural person consumers and customers and to disclose to such persons policies and procedures for protecting that information.

FI has adopted the requirements and target objectives set forth in this Consumer and Customer Information Privacy Policy Statement and Compliance Procedures (“Privacy Policies and Procedures”), which govern the activities of each officer, director, trustee and employee of FI.

Federal law requires the following:

  • FI may only in limited instances disclose nonpublic information about a consumer to nonaffiliated third parties;
  • FI must disclose to all consumers the privacy policies and practices with respect to information sharing with affiliated and nonaffiliated third parties; and
  • FI must establish procedures to ensure the protection of consumer information.

To ensure that privacy disclosure laws are not violated, FI has adopted the requirement and target objectives set forth in these Privacy Policies and Procedures. These requirements and target objectives are intended to describe FI's policies, educate employees about related issues and FI's policies, establish procedures for complying with these policies, and monitor compliance with these policies and procedures. Any doubts about the confidentiality of client information must be resolved in favor of confidentiality. Examples could include basic information such as age and telephone number as well as other identifying information about the customer.

Glossary

  • Consumer – an individual or an individual's legal representative that obtains or has obtained a financial product or service to be used primarily for personal, household or family purposes. A person becomes a consumer even if a questionnaire or application is withdrawn or denied or an advisory agreement does not become effective.
  • Customer – a consumer that has an ongoing relationship with FI, whereby FI is providing one or more financial products or services to the consumer, e.g., an advisory client or a shareholder of a Fund.
  • Nonpublic personal information –
    • All personally identifiable financial information.
    • Any list, description, or other grouping of consumers (and publicly available information pertaining to them) that is derived using any nonpublic personally identifiable financial information that is not publicly available information. The G-L-B Act excludes publicly available information – e.g., a list of persons (and their publicly listed telephone numbers) who have disclosed assets or wealth in excess of $100,000.

Requirement

No confidential information, whatever the source, regarding any FI customer, may be disclosed except as follows:

  • To other FI employees in connection with FI's business.
  • To an affiliate, but the affiliate may disclose the information only to the same extent as FI.
  • To nonaffiliated third parties with whom FI has a contractual agreement to jointly offer, endorse or sponsor a financial product or service; and to service and maintain customer accounts including effectuating a transaction.