PRIVACY POLICY | Hilbert8

DISCLOSURES TERMS OF USE PRIVACY POLICY ADV Part 3

We at HILBERT 8 respect your concerns about privacy. Registered investment advisers like HILBERT 8 are required by U.S. federal law to inform our clients of our policies to protect the privacy of client information. It also requires us to tell our clients how we collect, share, and protect personal information.

To administer, manage, service, and provide related services for client accounts, it is necessary for HILBERT 8 to provide access to client information within our firm and to nonaffiliated companies, with whom we have entered into agreements with. To provide the best service, HILBERT 8 may disclose the information below regarding clients and former clients, as necessary, to nonaffiliated companies to perform certain services on our behalf with your prior authorization.

In situations where HILBERT 8 discloses client information to nonaffiliated third parties, other than permitted or required by law, clients must be given the opportunity to opt out or prevent such disclosure. HILBERT 8 does not share or disclose client information to nonaffiliated third parties except as permitted or required by law.

We define affiliates as companies related by common ownership or control (such as our hedge fund). They can be financial and non-financial companies. We call nonaffiliates companies not related to HILBERT 8 by common ownership or control (such as third parties). They can be financial and non-financial companies. HILBERT 8 trains all employees to respect client privacy and to recognize the importance of confidentiality.

HILBERT 8 is committed to safeguarding the confidential information of our clients and prospective clients, past and present. HILBERT 8 holds all personal information provided by clients in the strictest confidence and it is our objective to protect the privacy of our clients. Except with explicit client approval when clients instruct us to or when clients enter into formal agreements with HILBERT 8, and as permitted or required by law, we do not share confidential information about clients with nonaffiliated parties. In the event that there were to be a change in this policy, we will provide clients with written notice and clients will be provided an opportunity to direct us as to whether such disclosure is permissible.HILBERT 8 is bound by professional standards of confidentiality that are even more stringent than those required by law.

Types of Nonpublic Personal Information (NPI) we collect

In order to conduct our regular business, HILBERT 8 collects NPI about clients that is either provided to us by you or obtained by us with your authorization. This can include but is not limited to:

NPI reported by the client in our Investment Advisory Contract (IAC), or other documents the client provides us in order for us to open and maintain a portfolio or account
NPI provided to us verbally
NPI about the client’s investment holdings and transactions implemented by us or others
NPI developed as part of routine reports, analyses, or investment advisory services
NPI received with prior client authorization from custodians and other service providers
Personal ID details, Date of birth, Contact details, Tax ID number, Social security number, Banking information, Financial account numbers/balances, Sources of income, Liabilities, Credit card nos., etc.

To whom we disclose NPI

These are the parties that HILBERT 8 may share your NPI with:

everyday business purposes within our firm in order to provide services you have requested, such as: to advise you on your investments, process your transactions, maintain your account(s), respond to court orders and legal investigations
any party that you have specifically authorized us to do so
our affiliates’ everyday business purposes, your transactions and experiences
our own marketing, in order to offer our products and services to you
joint marketing with other financial companies (such as the bank or broker you use for working with us)

HILBERT 8 uses security measures that comply with federal law and we maintain administrative, technical, and physical safeguards in order to protect your personal information against unauthorized or unlawful access, use, disclosure, loss, destruction, or damage. Federal law allows you to opt out of sharing information for joint marketing to other financial companies, to our affiliates, and to nonaffiliates. State laws may give you additional rights to limit sharing. Please be reminded that our policy for all clients and prospective clients is to only share NPI with nonaffiliates that you have preapproved. If you are a new client, HILBERT 8 may begin sharing your information as per our privacy policy on the day you sign our IAC agreement. When you are no longer our client, we may continue to share your information as described in this notice and continue to treat your NPI with strict confidentiality. However, you can contact us at any time to limit our sharing.

This policy forms a part of our Form ADV Part 2A, which is available at https://adviserinfo.sec.gov/Firm/284577and upon emailed request to info@hilbert8.com. An edited version is reproduced here for your convenience.

We work hard to provide you with quality financial services, and we do it according to rigorous professional ethics. Please let us know if you have any questions. Your privacy is very important to us.

Website Privacy Policy Additional Items

Security of Your Information

HILBERT 8 employs industry standard security measures designed to protect the security of all information submitted through our website. However, the security of information transmitted through the internet can never be guaranteed. HILBERT 8 is not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of our website are responsible for maintaining the security of any password, user ID, or other form of authentication involved in obtaining access to password protected or secure areas of any of our website, including the client login area. In order to protect you and your data, we may suspend your use of our website, without notice, pending an investigation, if any breach of security is suspected. Access to and use of password protected and/or secure areas of the HILBERT 8 website are restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.

Changes to this Privacy Policy

The HILBERT 8 privacy policy is currently applicable as stated on this webpage. We may change this privacy policy from time to time in our discretion. Changes will be posted to this webpage. We encourage you to return to this webpage frequently so that you are aware of our current privacy practices. Your continued use of the HILBERT 8 website constitutes your acceptance of our privacy policy.

Special Provisions

Children

We do not knowingly collect or maintain personal information from any person considered a minor or under the age of eighteen. No parts of our website are directed to or designed to attract anyone under the age of eighteen.

Do Not Track

This website does not support Do Not Track (DNT) at this time. DNT is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the webpage. For all the details, including how to turn on DNT, visit www.donottrack.us.

An internet ‘cookie’ is a small file containing a string of characters that is sent to your computer when you visit our website. When you visit this website again, the cookie allows this site to recognize your browser. Cookies may store unique identifiers, user preferences, and other information. Cookies help HILBERT 8 improve this website by providing us with information about which parts of the website are most popular, enabling us to analyze technical and navigational information about the website; and helping us and our nonaffiliated service provider to detect and prevent fraud. We also use cookies and other data collection tools (such as web beacons and server logs) to help improve your experience with our website. For example, we use Google Analytics to help analyze how users use the HILBERT 8 website. The Google Analytics tool uses cookies to collect standard internet log information and visitor behavior information in an anonymous form. The information generated by the cookie about your use of our website (including IP address) is transmitted to Google. This information is then used by HILBERT 8 to evaluate visitors’ use of the website and to compile statistical reports on website activity. Web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, please visit www.allaboutcookies.org. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet, or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through our website.

Non-U.S. Visitors

All personal information we collect through this website is currently processed in the United States by us or by an authorized non-affiliate acting on our behalf. The HILBERT 8 website is currently hosted in the United States. When you provide personal information to us through our website, you consent to the transfer of your data to, and processing of your data in, the United States.

Anonymized Data

You can visit this site to read about our firm and its products and services, without giving us any personal information about yourself. We may collect anonymous, aggregate technical information about how our site is accessed by you, such as IP address, domain name, time spent at the site, or web pages visited, but we do not collect your personal information unless you disclose it to us (i.e., registering, using the “contact us” feature, or subscribing to email distribution lists).