IM GLOBAL PARTNER FUND MANAGEMENT, LLC
LITMAN GREGORY FUNDS TRUST
(as amended September 30, 2022)
We have adopted general policies and procedures concerning confidentiality, proprietary data and privacy of customer personal information, and the information we gather over the Site is protected by those policies and procedures. Generally, we collect non-public personal information about our clients from the following sources:
- Information from forms (such as the Account Application and Investment Management Agreement) you fill out and send to us in connection with your investments managed by iM Global Partner Fund Management, LLC (IMGPFM) (such as your name, address, and social security number);
- Information you provide orally to us or our representatives;
- Information about the amounts you have managed by IMGPFM (such as your initial investment and any additions to and withdrawals from your accounts);
- Information from electronic sources such as our Web sites or e-mails; and,
- Information about any bank account you use for transfers between your bank account and your account(s) with IMGPFM.
- Information about any bank account you use for transfers between your bank account and your capital account in the Trust.
Our policy is that we do not disclose any non-public personal information about our current or former clients to anyone, except as permitted by law. We may voluntarily disclose non-public personal information about our current or former clients to regulatory authorities in connection with our business or that of our affiliates. In addition, we share non-public personal information with certain service providers to the extent permitted by law, and we require those service providers to keep the non-public information confidential. For example, we may provide such information to brokers, attorneys, third-party marketing firms and auditors.
- We restrict access to non-public personal information about our clients to employees and service providers who need to know that information to provide services to our clients.
- We maintain physical, electronic and procedural safeguards that comply with federal standards to guard clients’ personal information.
II. Collection of Information
In general, you can browse the Site without telling us who you are or revealing any personal information about yourself. We automatically track certain information that your browser makes available whenever you visit a website. This information includes your Internet Protocol address, browser type, browser language and one or more files that may uniquely identify your browser. We may use this information to do internal research on our users’ demographics, interests and behavior to better understand, protect and serve you and our clients. This information may include the URL from which you just came (whether this URL is on the Site or not), to which URL you next go (whether this URL is on the Site or not), your computer browser information and your IP address. We use this information to operate, develop and improve our services. If you wish to contact us through our website, we will also collect your name, email address, and phone number.
III. Use and Disclosure of Information
We may use your information to send correspondence and perform services on your behalf in connection with investment-related activities.
We may use personal information about you to analyze Site usage, improve our content and product offerings and customize the Site’s content, layout, and services. These uses improve the Site and better tailor it to meet your needs, so as to provide you with a smooth, efficient and safe experience while using the Site.
In providing our services, we also may share personal information about you with other third parties to help us process transactions relating to your account, including, but not limited to, asset transfers from a financial institution and processing or administering investment transactions and portfolios. In certain instances, we may contract with third parties that are not affiliated with us to perform services for us, and, if necessary, we may disclose information about you to those third parties solely for the purpose of carrying out their assigned responsibilities. In those circumstances, we require those third parties to treat your private information with the same degree of confidentiality that we do. In some instances, the third-party service provider may collect information directly from you. In these cases,
We may also share information about you if we believe that disclosure is required under law. For example, we may disclose information in response to a subpoena or to cooperate with regulatory or law enforcement authorities.
IV. Control of Your Personal Information
You can review and change any information you submit to us by contacting us at (424) 277-1066.
Your information is stored on our servers located in the United States. We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy, which may include encryption, “firewalls”, Secure Sockets Layer (SSL) and Transport Layer Security (TLS). We treat data as an asset that must be protected against loss and unauthorized access. We employ security techniques to protect such data from unauthorized access by users inside and outside the firm.
A third party may circumvent our security measures, however, and we do not guarantee that our security measures will successfully prevent third parties from accessing the information we collect. In the event of a security breach involving your personal information, we will make any legally required disclosures to you in the most expedient time possible and without unreasonable delay, consistent with the legitimate interests of law enforcement, or any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information or social security number in an unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
Persons under the age of 18 are not eligible to use the Site and, therefore, we do not knowingly collect any personal information from persons under the age of 18.
VIII. Conditions of Use
IX. Privacy Rights – California
If you are a resident of California, you may have rights under the California Consumer Privacy Act of 2018 (“CCPA”), as described in this section of our Privacy Notice.
A. Your Right to Request Disclosure of Information We Collect and Share About You
The Company is committed to ensuring that you know what information we collect and share about you. You can submit a request to the Company for the following information:
- The categories of Personal Information that we have collected about you.
- The categories of sources where we collected the Personal Information.
- The business or commercial purposes for why we collected the Personal Information.
- The specific pieces of information we collected.
- The third parties with whom we shared the information.
- The categories of Personal Information that we’ve shared with service providers who provide services for us.
To exercise the right to request the disclosure of Personal Information that we collect or share about you, contact us at firstname.lastname@example.org or (424) 277-1066.
B. Categories of Personal Information We Disclose
We may disclose your Personal Information to a third party for a business purpose.
C. Categories of Personal Information We Sell
We do not sell your Personal Information to any third party for a business purpose.
D. Our Process for Responding to Requests for Access or Deletion under the CCPA
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
To respond to your request, we will ask you for certain pieces of personal information and endeavor to match those to information we maintain about you. The nature and number of verifying data elements we may request will depend on the nature of your request and the nature of the information we maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. In that case, we will notify you to explain the basis of our denial.
If you are legally entitled to such rights, you may designate an agent to submit a request on your behalf. The agent can be a natural person or a business entity that is registered with the California Secretary of State. If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our agent verification process.
For requests for access or deletion, we will respond to your request or your authorized agent’s request in writing, or verbally if requested, as soon as practicable and in any event generally not more than within 45 days after receipt of the request. We may extend this period to 90 days and, in the event that we do extend the period, we will explain to you or your authorized agent why we did so.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
You have a right not to be discriminated against for the exercise of the privacy rights conferred by the CCPA.
F. Do Not Track
California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how a website operator responds to “Do Not Track” (“DNT”) browser settings. DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third party ad networks, social networks and analytic companies. We do not currently take actions to respond to DNT signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a DNT standard once one is created. For information about DNT, visit All About DNT.
G. Shine the Light
California’s “Shine the Light” law, Cal. Civil Code §1798.83, gives California customers the right to prevent our disclosure of their Personal Information to third parties for those third parties’ direct marketing purposes, and requires certain businesses to respond to requests from California customers asking about the business’ practices related to disclosing Personal Information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose Personal Information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place.
X. Changes to this policy
XI. The Advisor
The Company has overall responsibility for assets under management, recommends the selection of managers as sub-advisors of the Funds (each, a “manager” or “sub-advisor”) to the Board of Trustees (the “Board”) of the Litman Gregory Funds Trust (the “Trust”), evaluates the performance of the managers, monitors changes at the managers’ organizations that may impact their abilities to deliver superior future performance, determines when to rebalance the managers’ assets and the amount of cash equivalents (if any) that may be held in addition to cash in each of the managers’ sub-portfolios, coordinates with the managers with respect to diversification and tax issues and oversees the operational aspects of the Funds.
If you have any additional questions, please feel free to contact us any time at (424) 277-1066.