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SEC Regulation S-P (Privacy of Consumer Financial Information), which was adopted to comply with Section 504 of the Gramm-Leach-Bliley Act, requires investment advisers to disclose to their clients/investors, who are natural persons, its policies and procedures regarding the use and safekeeping of client/investors records and information.

BRAM will not disclose client/investor records and information including non-public personal information and consumer report information (collectively, “client/investor information”) to anyone unless such disclosure is permitted or required by law.


1. BRAM shall not sell client/investor information to anyone.

2. BRAM will restrict access to client/investor information to individuals within BRAM who require the information in the ordinary course of servicing clients/investors accounts. lient/Investor
information is used only for business purposes.

3. BRAM has developed procedures to safeguard client/investor records and information (See Attachment A).

4. Client/investor information may only be given to third-parties under the following circumstances:

      • To other firms as directed by clients/investors, such as accountants, lawyers, etc.;
      • To specified family members (as authorized by law and/or the client/investor);
      • To third-parties as needed to provide requested services; and
      • To regulators and others, when required by law.

5. At times, client/investor information may be reviewed by BRAM’s outside service providers (e.g., accountants, lawyers, consultants, administrators, etc.). BRAM will review the entity’s privacy policies to ensure that client/investor information is not misappropriated or used in a manner that is contrary to this privacy policy.

6. BRAM shall provide a Privacy Notice (See Attachment B) to clients/investors upon inception of the relationship and annually thereafter. The Privacy Notice shall be furnished to clients/investors in a written format and BRAM will maintain a record of the dates when the Privacy Notice is provided to clients/investors. Prior to October 1, 2007, this Privacy Notice was furnished to clients within Form ADV Part II.

7. In the event of a change in the Privacy Policy, BRAM will provide its clients/investors with a sufficient amount of time to opt out of any disclosure provisions.

8. Any suspected breaches to the Privacy Policy must be reported to the CCO as soon as possible.

9. If an employee receives a complaint regarding a potential identity theft issue (be it from a client/investor or other party), the employee should immediately notify the CCO. The CCO will thoroughly investigate any valid complaint (refer to the client/investor complaint policy), and maintain a log of all complaints as well as the result of any investigations.

10. Extraneous documents containing any client/investor information or sensitive consumer information shall be shredded or destroyed.

Only with written client consent may BRAM employees disclose information about clients to:

1. agent(s) that pay a referral fee (clients must sign a written acknowledgement before any such
referral fee can be paid); or

2. prospective future investors through representative client lists used in marketing presentations.

The CCO will monitor for compliance with the Privacy policy and procedures and will coordinate the
dissemination of the Privacy Notice

Get in Touch

BirdRock Asset Management
9433 Bee Caves Rd
Austin, TX 78733 

Phone: (512) 236-0071
Fax: 512-430-1346

ManagerDecade 4Q 2014