How and why we obtain personal information
Alpina Holdings takes great care to protect personal information about you and when we use it, we do so with respect for your privacy. We may use personal information about you to service, maintain, and protect your account; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; or to fulfill legal and regulatory requirements. Alpina Holdings may collect public and non-public personal information about you from any of the following sources:
• You or your representative on applications or forms (for example, name, address, Social Security number, birth date, assets and income (to determine accreditation in accordance with Rule 501 of Regulation D of the Securities Act of 1933 or in accordance with Regulation A of the Securities Act of 1933))
• You or your employer or plan sponsor if Alpina Holdings provides them with recordkeeping services (for example, payroll, human resources, or benefits information)
• Transactional activity in your account (for example, trading history and balances)
• Other interactions with Alpina Holdings (for example, discussions with our customer service staff or information you enter into our websites)
• Information from consumer reporting agencies
• Information from other third-party data services (for example, to verify your identity and to better understand your product and service needs)
• You or your representative regarding your preferences (for example, your choice of electronic statement delivery, or the screen layout you specify if you use our Internet sites)
• Other sources with your consent or with the consent of your representative (for example, from other institutions if you transfer positions into Alpina Holdings)
How we protect information about you
Alpina Holdings considers the protection of personal information to be a foundation of customer trust and a sound business practice. We employ physical, electronic and procedural controls and we regularly adapt these controls to respond to changing requirements and advances in technology.
At Alpina Holdings, we restrict access to personal information to those who require it to develop, support, offer and deliver products and services to you.
How we share information about you with third parties
Alpina Holdings does not share personal information about our customers with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities:
• Unaffiliated service providers (for example, printing and mailing companies, securities clearinghouses, marketing service providers, and other entities who may provide services at Alpina Holdings's direction)
• Government agencies, other regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions)
• Other organizations, with your consent or as directed by your representative (for example, if you use Alpina Holdings as a financial reference in applying for credit with another institution), or as permitted or required by law (for example, for fraud prevention)
Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by Alpina Holdings.
Based on the nature of your relationship with Alpina Holdings, we may exchange information with other third parties as described below:
• If Alpina Holdings provides workplace services to your employer or plan sponsor, such as payroll, human resources or benefits recordkeeping services, Alpina Holdings may exchange any information received in connection with such services with your employer or plan sponsor or others they may authorize.
• If you conduct business with Alpina Holdings through your investment professional, we may exchange information we collect with your investment professional or with others they may authorize.
How we share information about you within Alpina Holdings
We may share personal information about you with various Alpina Holdings corporate affiliates including internal service providers which perform, for example, printing, mailing, and data processing services.
Additionally, if you interact with Alpina Holdings directly as an individual investor (including joint account holders) or if Alpina Holdings provides services to your employer or plan sponsor, we may exchange certain information about you with financial services affiliates, such as our brokerage and insurance companies, for their use in marketing products and services as allowed by law.
Information collected from investment professionals' customers is not shared with Alpina Holdings affiliates for marketing purposes, except with your consent and as allowed by law.
Privacy, security, and service in Alpina Holdings's online operations are just as critical as in the rest of our business. We use firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect Alpina Holdings accounts and systems from unauthorized access.
When you interact with us through online channels (for example, websites and email) owned and controlled by Alpina Holdings, LLC ("Alpina Holdings websites"), Alpina Holdings manages personal information in accordance with all of the practices and safeguards described previously.
When you visit Alpina Holdings websites, we may collect technical and navigational information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on Alpina Holdings websites. We use this information for a variety of purposes, such as maintaining the security of your online session, facilitating site navigation, improving Alpina Holdings website design and functionality, and personalizing your experience on Alpina Holdings websites. Additionally, the following policies and practices apply when you are online.
Cookies and similar technologies
You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie when on a Alpina Holdings website, or if you delete cookies, you may experience some inconvenience in your use of Alpina Holdings websites. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device, or your online preferences.
Connecting with Alpina Holdings on social media sites
If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers.
Alpina Holdings offers several options for accessing and, if necessary, correcting your account information. You can review your information using your statements, or through our automated telephone or Internet services. You may also write or call us with your request for information. If we serve you through an investment professional, please contact them directly. Specific Internet addresses, mailing addresses and telephone numbers are listed on your statements and other correspondence.
• Information provided by you or your representative on applications or other forms furnished to the Fund or through other interactions that you or your representative have with the Fund
• Information arising from your investments in or accounts with the Fund
• Information the Fund receives from a consumer reporting agency
The Fund employs physical, electronic, and procedural controls to safeguard your information. For example, the Fund authorizes access to your personal and account information only for personnel who need that information in order to provide products or services to you. The Fund does not disclose any non-public personal information about you, except as permitted by law. For example, the Fund has entered into a number of arrangements with FundAmerica to provide for investment management, distribution and servicing of the Fund.
If you decide to no longer invest, the Fund will continue to adhere to the privacy policies and practices as described in this notice.
Effective February 2017