CLIENT PRIVACY STATEMENT
The relationship between Kanawha Capital Management, LLC and our clients is the most important asset of our firm. We strive to maintain your trust and confidence in our firm, an essential aspect of which is our commitment to protect your personal information to the best of our ability. We believe that all of our clients value their privacy, so we will not disclose your personal information to anyone unless it is allowed by law, is at your direction, or is necessary to provide you with our services. This statement describes how we protect the confidentiality of the personal information you share with us, the types of information we collect, and how we use it.
The information we collect is limited to that which is useful to conduct our business and to provide services to you; to protect and administer your records, accounts and funds; to comply with regulatory laws and regulations; to help us design or improve our services and to understand your financial needs so we can provide you with superior service. Information comes from the following sources:
• Information we receive from you when you enter into an investment advisory contract and open a new account (such as your social security number, home address, telephone number, and income);
• Information we receive from you to provide investment advice (such as investment experience and risk tolerance);
• Information that we generate to service your account (such as transaction history, tax information, trade tickets and account statements); and
• Information that we may receive from third parties with respect to your account (such as account balances and trade confirmations from brokerage firms).
INFORMATION WE SHARE
We want you to be fully assured that we do not sell information or client lists to third parties. We do not share information about any clients or former clients other than described below.
INFORMATION TO PARENT COMPANY AND AFFILIATES
We may share information with our parent company, HighTower Advisors, LLC, and its board. Included in this information is summary data about our accounts, specifically account balances and advisory fees.
SHARING INFORMATION WITH COMPANIES THAT WORK WITH US
In order to conduct company business and to offer products or services that may complement your relationship with us, we may share some of the information we collect, as described above, with companies or affiliates that perform services for us on your behalf, such as vendors we hire to prepare account statements or to provide support for one or more of our products and services; technology consultants who assist us in maintaining our computer systems; Chicago Clearing Corporation to administer class action litigation paperwork; or your brokers and custodians to whom we provide account information. Written obligations are generally in place to keep the information we provide confidential and to use the information only for the purpose authorized.
We may also include periodic account statements for accounts with a common mailing address in a single envelope for convenience. This is commonly known as “householding” and may include other family or related accounts with the same mailing address. This will be done as requested or consented to by the account holders.
In addition, we provide a list of our clients’ names and addresses to Enstrom’s Candies, which annually mails a year-end gift from us to our clients. If you do not want us to include your name on this list, please call us at (804) 359-3900.
SHARING INFORMATION IN OTHER SITUATIONS
We may share some or all of the information we collect, as described above, or as otherwise authorized or required under applicable law. This includes, for example, disclosures to process and service your requested or authorized transactions; disclosures in connection with subpoenas or other legal processes; disclosures as part of fraud or other investigations; disclosures in connection with audits and examinations; and disclosures pursuant to your authorization or consent.
PROTECTING INFORMATION ABOUT YOU