Keala Advisors Privacy Policy

Keala Advisors LLC (“Keala”, “firm”, “we”, or “our”), as a Registered Investment Adviser, values the trust our clients have placed in us and are committed to the responsible management, use, and protection of their personal information.

This “Privacy Policy” describes how we collect, store, use, disclose and protect your personal information that may directly, or indirectly, identify you during and after your working relationship with us and/or through our “Website.” We use the term “Personal Information” to describe information that can be associated with you and can be used to identify you. Personal Information does not include information that does not identify a specific person or that is publicly available. In particular, this Privacy Policy describes the basis upon which and for what purposes we process your Personal Information, how we share your Personal information and how we protect and safeguard your Personal Information.

Why We Collect  Personal Information. To conduct regular business, Keala collects personal information about its customers to help it serve their financial needs, process transactions in their account(s), provide customer service, offer new products or services, and fulfill legal and regulatory requirements.

Information We Collect From our Website:

When visitors to our site leave comments or send messages through our website, we collect the data shown in the comments form along with your IP Address and Online Identifier Information.  

Information We Collect From Clients:

• social security or taxpayer identification numbers 
• name, address, phone number
•  email address(es)
•  information and records pertaining to personal background
• investment experience, goals and objectives
•  financial information
•  tax information
•  investment holdings
• account numbers
• account balances

Additional Information Maintained:

• information about transactions implemented by the firm or others
• information developed as part of financial strategies, analyses, or investment advisory services
• information gathered regarding transaction history by the firm such as services purchased, investments, account balances, trading history, and payment history.

Personal Information we may collect from other sources:

• custody, brokerage and advisory agreements
• legal documents 
• account applications and forms 
• investment questionnaires and suitability documents 
• transaction information with us or others 
• other information needed to service the account.

Commitment to Your Private Information.

 Keala is committed to safeguarding the confidential information of its clients.  Keala holds all Personal Information provided by clients and other sources in the strictest confidence and it is the objective of the firm to protect the privacy of all clients.  The staff of Keala realizes that providing Personal Information is an act of trust.  Keala values its clients’ trust and confidence.  We will never sell or share the nonpublic personal information obtained from or in reference to clients.  Additionally, we will not sell or share your Personal Information for marketing purposes.  All information provided by clients to Keala and its staff or information received from other sources, and information and advice furnished to clients by us, shall be treated as confidential and shall not be disclosed to affiliated or unaffiliated third parties, except as permitted or directed by clients with written authorization, by application to facilitate the investment services offered by the firm via an affiliated or unaffiliated financial services provider, or as required by any rule, regulation or law.

It is our policy to restrict access to all current and former clients’ information to those employees and affiliated/non-affiliated entities who need to know that information in order to provide products or services in furtherance of the client’s engagement of Keala.  Keala permits only authorized employees and affiliates who have acknowledged receipt and understanding of our Privacy Policy (by acknowledging and accepting our firm’s Compliance Policies and Procedures) to have access to client information.  Employees, agents or affiliates violating Keala’s Privacy Policy will be subject to our disciplinary process. 

Sharing Information with Other Companies Permitted Under Law. 

To administer, manage, service, and provide related services for client accounts, it is necessary for Keala to provide access to client information within the firm and to nonaffiliated companies, with whom we have entered into agreements.  Since Keala shares nonpublic information solely to service client accounts, the firm does not otherwise disclose any nonpublic personal information about the firm’s customers or former customers to anyone, except as stated in this policy or permitted by law. 

Keala may disclose the client’s information: (1) to individuals and/or entities not affiliated with Keala, including, but not limited to the client’s other professional advisors and/or certain service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, record keeper, proxy management service provider, etc.) that may be recommended or engaged by Keala in furtherance of the client’s engagement of Keala; (2) to provide the client with marketing materials regarding our services, as well as those offered pursuant to joint agreements with our affiliates or non-affiliated third parties, so long as all parties offering the products and/or services have agreed, in writing, to protect the confidentiality of the customer’s information and to not use it for any other purpose; (3)  as otherwise necessary in the course of effectively implementing its services; (4) enforce any of our rights, including the collection of any fees or other payments due; (5) as reasonably required pursuant to the proposed or actual sale, merger, transfer, or exchange of all, or a portion of, our business   (6) required to do so by judicial or regulatory process; or (7) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. 

Automatic Authorizations.  

The disclosure of Personal Information contained in any document completed by the client for processing and/or transmittal by Keala to facilitate the commencement/continuation/termination of a business relationship between the client and/or between Keala and a non-affiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, record keeper, insurance company, etc.), including, but not limited to, information contained in any document completed and/or executed by the client in furtherance of the client’s engagement of Keala (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding non-affiliated third-party service provider.

Procedures to Protect Confidentiality and Security of Your Personal Information

Keala has procedures in place that limit access to Personal Information to those employees, agents or affiliates, who need to know such information in order to perform business services. In addition, Keala maintains physical, electronic and procedural safeguards to guard your Personal Information.  Keala has also adopted the following policies in order to safeguard the Personal Information of our clients in accordance with applicable law:

1. Keala collects and will handle Personal Information about clients only in accordance with all applicable laws, rules and regulations. We shall ensure: (a) the security and confidentiality of client records and information; (b) that client records and information are protected from any anticipated threats and hazards; and (c) that unauthorized access to, or use of, client records or information is protected against. These security measures include computer safeguards and secured files and buildings.
2. Keala will maintain policies and procedures that are reasonably designed to safeguard Personal Information about clients and only permit appropriate and authorized access to, and use of, Personal Information about clients through the application of appropriate administrative, technical, and physical protections.
3. To the extent required by applicable law, we shall direct each of our service providers to adhere to Keala’s Privacy Policies with respect to all Personal Information provided to such service providers.
4. Keala shall not disclose any Personal Information about its clients or former clients to anyone, except as permitted or required by law.
5. Keala shall issue notices of its Privacy Policy to its clients initially and thereafter to the extent required by applicable law.

Linking to Third Party Websites. We may provide links to third party websites.  If you follow links to third-party websites not affiliated or controlled by Keala, you should review that third-party’s privacy and security policies and other terms and conditions, as they may be different from our Privacy Policies and Notice. We do not guarantee and are not responsible for the privacy or security of these third-party websites, including the accuracy, completeness, or reliability of their information.

Children. Our Website is not directed or intended for individuals under the age of thirteen (13), and we request that these individuals do not provide personal information through the Website. We do not knowingly collect or retain information from children under the age of 13 without parental consent. Visit the Federal Trade Commission website for more information about the Children’s Online Privacy Protection Act (COPPA).

Former Clients. Even if we cease to provide you with financial products or services, our Privacy Policy will continue to apply to you, and we will continue to treat your nonpublic information with strict confidentiality.

Changes to this Policy. Keala will provide each client with initial notice of the firm’s current Privacy Policy when the client relationship is established.  We will also provide each client with a new notice of the firm’s current Privacy Policy as required by law.  If, at any time, Keala adopts material changes to its privacy practices, the firm shall provide each client with a revised notice reflecting the new privacy practices.  We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify our clients and provide each client with an opportunity to prevent the information sharing. 

Contact Us:  Clients are encouraged to discuss any questions regarding privacy policies and procedures directly with Christopher J.P. Mitchell, Chief Compliance Officer of Keala Advisors Advisors.  Contact information: chris@keala.io or 929-235-8201.

By disclosing your Personal Information to Keala, you consent to the collection, storage, and processing of this information by us in a manner consistent with this Privacy Policy and Notice.