SEC REGISTRATION: Highline is a U.S. Securities and Exchange Commission ("SEC") Registered Investment Advisor ("RIA"). SEC registration is required for RIA's that have more than $25 million under management. A copy of Highline’s Form ADV-Part II is provided to all clients and prospective clients.
NO OFFER: Nothing on the Highline website should be construed as a solicitation, or offer, or recommendation, to acquire or dispose of any investment or to engage in any other transaction. Highline does not render or offer to render personalized investment advice or financial planning advice through the Highline website. Highline advice is given only within the context of our contractual agreements with each client. The Highline website is limited to the dissemination of general information about Highline service offerings, and provides an alternative method for clients and prospective clients to learn more about Highline, and to contact Highline. Advice may only be rendered after the delivery of Form ADV-Part II and the execution of an investment advisory agreement by the client and Highline.
NO RELIANCE: While Highline uses reasonable efforts to obtain information from sources which it believes to be reliable, Highline makes no representation that the information or opinions contained on the Highline website is accurate, reliable or complete. The information and opinions contained in the Highline website are provided by Highline for personal use and informational purposes only and are subject to change without notice. Nothing contained on the Highline website constitutes investment, financial, legal, tax or other advice nor is it to be relied on in making an investment or other decision. Highline specific advice is given only within the context of our contractual agreements with each client.
LINKED WEBSITES: When you access certain links on the Highline website you may leave the Highline website. Highline does not endorse the content of such websites nor the products, services or other items offered through such websites. Any links to other sites are not intended as referrals or endorsements, but are merely provided to the users of the Highline website for convenience and informational purposes.
DOWNLOADED MATERIAL FROM WEBSITE: You may download or print out a hard copy of individual pages and/or sections of the Highline website, and files made available for download, provided that you do not remove any logos or other proprietary notices. Any downloading or otherwise copying from the Highline website will not transfer title to any software or material to you. You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link into or use for any public or commercial purpose the Highline website without the prior written permission of Highline.
The services provided in this Web site are intended for persons who reside in the U.S.
PRIVACY NOTICE
ISSUE
The SEC’s 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 clients its policies and procedures regarding the use and safekeeping of personal information.
Personal information is collected from clients at the inception of their accounts and occasionally thereafter, primarily to determine accounts’ investment objectives and financial goals and to assist in providing clients with a high level of service.
While Highline strives to keep client information up to date, clients are requested to monitor any information provided to them for errors.
RISKS
In developing this policy and procedures, Highline considered the material risks associated with protecting non-public personal information. This analysis includes risks such as:
- Information about activities of Highline and its Clients that is required to be maintained is not accurately recorded and stored and is not protected from unauthorized access, alteration, and destruction.
- Information about clients is not maintained or used in ways that ensures such information is safe from unauthorized use.
- False or misleading disclosures are made to clients about how their non-public personal information is used and protected from unauthorized use.
- Highline’s service providers do not adequately safeguard client information.
Highline has established the following guidelines as an attempt to mitigate these risks:
POLICY
Highline will not disclose a client’s personal information to anyone unless it is permitted or required by law, at the direction of a client, or is necessary to provide Highline’s services.
PROCEDURES
1. Highline shall not sell client information to anyone.
2. Highline will restrict access to clients’ personal information to individuals within Highline who require the information in the ordinary course of servicing clients’ accounts. Client information is used only for business purposes.
3. Highline has developed procedures to safeguard client records and information (See Attachment A).
4. Client information may only be given to third-parties under the following circumstances:
- To broker/dealers to open a client’s brokerage account;
- To other firms as directed by clients, such as accountants, lawyers, etc.;
- To specified family members; and
- To regulators, when required by law.
5 At times, client information may be reviewed by Highline’s outside service providers (i.e. – accountants, lawyers, consultants, etc.). Highline will review the entities’ privacy policies to ensure that clients’ information is not misappropriated or used in a manner that is contrary to Highline’s privacy policies.
6. Highline shall provide a privacy notice (See Attachment B) to clients (i.e. “natural persons”) upon inception of the relationship and annually thereafter. Highline will maintain a record of the dates when the privacy notice is provided to clients.
7. In the event of a change in the privacy policy, Highline will provide its clients with a sufficient amount of time to opt out of any disclosure provisions.
8. Any suspected breaches to the privacy policy should be reported to the Compliance Officer.
9. If an employee receives a complaint regarding a potential identity theft issue (be it from a client or another party), the employee should immediately notify the Compliance Officer. The Compliance Officer will thoroughly investigate any valid complaint, and maintain a log of all complaints as well as the result of any investigations.
10. In the event that unintended parties receive access to personal and confidential information of California residents, Highline will disclose those clients of the privacy breech.
RESPONSIBILITIES
The Compliance Officer will monitor for compliance with Highline’s Privacy Policy and coordinate the dissemination of the Privacy Notice.
