It is the policy of GSF to restrict
access to all current and former clients’ information (i.e.,
information and records pertaining to personal background, investment
objectives, financial situation, tax information/returns, investment
holdings, account numbers, account balances, etc.) to those employees
and affiliated/nonaffiliated entities who need to know that information
in order to provide products or services to the client. GSF may disclose
the client’s information if GSF is: (1) previously authorized to
disclose the information to individuals and/or entities not affiliated
with GSF, including, but not limited to the client’s other professional
advisors and/or service providers (i.e., attorney, accountant, insurance
agent, broker-dealer, investment adviser, account custodian, etc.); (2)
required to do so by judicial or regulatory process; or (3) otherwise
permitted to do so in accordance with the parameters of applicable
federal and/or state privacy regulations. The disclosure of information
contained in any document completed by the client for processing and/or
transmittal by GSF in order to facilitate the
commencement/continuation/termination of a business relationship between
the client and a nonaffiliated third party service provider (i.e.,
broker-dealer, investment adviser, account custodian, insurance company,
etc.), including information contained in any document completed and/or
executed by the client for GSF (i.e., advisory agreement, client
information form, etc.), shall be deemed as having been automatically
authorized by the client with respect to the corresponding nonaffiliated
third party service provider.
GSF permits only authorized employees and affiliates who have signed a
copy of GSF’s Privacy Policy to have access to client information.
Employees violating GSF’s Privacy Policy will be subject to GSF’s
disciplinary process. Additionally, whenever GSF hires other
organizations to provide services to GSF’s clients, GSF will require
them to sign confidentiality agreements and/or the Privacy Policy.
Should you have any questions regarding the above, please contact Daniel
A. Kurtz, Chief Compliance Officer.