Clearbrook Investment Management, LLC

Privacy Policy

Our Privacy Policy applies to current and former clients. Throughout the policy, we refer to information that personally identifies clients or client accounts as "personal information."

  1. We collect personal information in the normal course of business to better manage and serve our clients.

    • We collect our clients’ information (that they provide to us) when they open an account or register for one of our services. The information we collect may include the client’s name, address, phone number, e-mail address, social security number, and information about the client’s interests, investments, and investment experience.

    • Once a client opens an account with us, we collect and maintain personal information about the client’s transaction history, positions, and account balances. We may include the client’s name and other data in internal data bases and lists that reflect the client’s activities at Clearbrook.

  2. We use personal information to fulfill our regulatory and audit obligations and to help us deliver the best possible client service.

  3. We do not sell personal information to anyone.

  4. We do not disclose personal information to third parties, unless one of the following limited exceptions applies:

    • We disclose personal information to companies that help us process or service client transactions or account(s), including the custodian. We have contracts with these companies that prohibit them from using personal information for their own purposes.

    • 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: to cooperate with regulatory or law enforcement authorities, to resolve consumer disputes, to perform credit/authentication checks, or for institutional risk control.

    • Outside of these exceptions, we will not share personal information with third parties unless the client specifically requests us to do so.

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

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

  6. We continue to evaluate our efforts to protect personal information and make every effort to keep personal information accurate and up-to-date. If clients identify any inaccuracy in their personal information, or need to make a change to that information, they should contact us so that we may promptly update our records.

  7. We will provide notice of changes in our information sharing practices. If, at any time in the future, it is necessary to disclose our clients’ personal information in a way that is inconsistent with this policy, we will

    Revised 12/3/2015 give them advance notice of the proposed change so they can opt out of such information sharing. Clients with any questions or concerns may call us at (360) 820-3712 or e-mail: ben@clearbrookinvestments.com.