At Hilton Capital Management, LLC (“Hilton”) your privacy is our priority. Our most important asset is our relationship with you. We understand that you have entrusted us with your private financial information, and we do everything we can to maintain that trust.

At Hilton:

  • We do not sell your personal information to anyone.
  • You are automatically opted out from sharing personal information with third parties.
  • We are committed to safeguarding your personal and financial information.

Details of our approach to privacy and how your personal information is collected and used are set forth in the Hilton Privacy Policy below.

 

Privacy Policy

The Hilton privacy policy applies to consumers who are current or former Hilton clients. Throughout the policy, we refer to information that personally identifies you or your accounts as "personal information."

  1. We do not sell your personal information to anyone.


  2. The law allows you to "opt out" of only certain kinds of information sharing with third parties. Hilton does not share personal information about you with any third parties except for specific purposes described below, that triggers this opt out right. This means YOU ARE ALREADY OPTED OUT. Hilton only shares personal information with third parties in the following limited circumstances:

    We disclose personal information to companies that help us process or service your transactions or account(s), including but not limited to, companies that clear and process your transactions, print and mail your account statements, verify your identity, consumer reporting agencies, third party software vendors and other financial institutions that Hilton contracts with to service your account. This information may relate to the Clients finances, employment, avocations or other personal characteristics, such as, the Client’s first and last name, address, phone number, social security number, and email address, as well as transactions and interactions with or through the Company or with others . The Company may also collect information about what Clients have entered into, viewed on and/or downloaded from the Company’s website.

    Sometimes we enter into contracts with third parties so that they can assist us in servicing your account. The contracts prohibit them from using any of your personal information for their own purposes, and the third parties are required to maintain the confidentiality of the information we have provided to them.

    We may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required or permitted under law. For example, we may be required to disclose personal information to cooperate with regulators or law enforcement authorities, resolve consumer disputes, perform credit/authentication checks, or for institutional risk control.

    For regulatory purposes, regulatory organizations including the NFA, CFTC and SROs require access to personal information of current and former clients, employees, agents, directors, officers, partners and others that has been collected or used by Regulated Persons. SROs collect, use or disclose such personal information obtained from Regulated Persons for regulatory purposes, including:
    • Surveillance of trading-related activity,
    • Sales, financial compliance, trade desk review and other regulatory audits,
    • Investigation of potential regulatory and statutory violations,
    • Regulatory databases,
    • Enforcement or disciplinary proceedings,
    • Reporting to securities regulators, and
    • Information-sharing with securities regulatory authorities, regulated marketplaces, other self-regulatory organizations and law enforcement agencies in any jurisdiction in connection with any of the foregoing.


  3. We collect personal information in the normal course of business in order to administer your accounts and serve you better.

    • Application and registration information. We collect information that you provide to us when you open an account. The information we collect may include name, address, phone number, email address, social security number, and information about your interests, investments, and investment experience. We also may collect information from consumer reporting agencies to verify your identity in the account opening process.

    • Anti-Money Laundering. To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account. What this means to our Clients: When a Client opens an account; we will ask the Client for their name, address, date of birth and other information that will allow the Company to identify the Client. The Company may ask to see the Client’s driver’s license or other identifying documents. The Company may also seek to verify the information the Client provides by checking various databases.

    • Transaction information. Once you have an account with us, to administer your account and better serve you, we collect and maintain personal information about your transactions, including balances, positions, and history, and may include your name or other data in an internal client list that reflects your activities at Hilton.


  4. We use your personal information to help us deliver the best possible service to you.

    To understand your financial needs and to deliver financial products and services that meet them, we may share personal information, such as transaction or experience data, with various service providers, all of which follow similar privacy policies.


  5. We protect the confidentiality and security of your personal information.

    • Companies we hire to provide support services are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to the performance of the specific service we have requested.

    • We restrict access to personal information to our employees and agents for business purposes only. All employees are trained and required to safeguard such information.

    • We maintain physical, electronic, and procedural safeguards to guard your personal information.


  6. We continue to evaluate our efforts to protect personal information and make every effort to keep your personal information accurate and up to date.

    If you identify any inaccuracy in your personal information, or you need to make a change to that information, please contact us so that we may promptly update our records.


  7. We will provide notice of changes in our information-sharing practices.

    The Company reserves the right to change this Privacy Policy at any time. The examples contained within this Privacy Policy are illustrations and are not intended to be exclusive. This notice complies with a recent Federal and State law and regulations regarding privacy. A Client may have additional rights under other foreign or domestic laws that may apply.

    If, at any time in the future, it is necessary to disclose any of your personal information in a way that is inconsistent with this policy, we will give you advance notice of the proposed change so that you will have the opportunity to opt-out of such disclosure.

 

If you have any questions or concerns, please feel free to contact us.