Home  >  Privacy Policy

INFORMATION PRIVACY POLICY - July 2023

Introduction

Pursuant to the Commodity Futures Trading Commission rules, financial institutions like Eclipse Capital Management, Inc. (hereafter referred to as the Firm) are required to provide privacy policy notices to clients who are individuals and use the firm's products and services primarily for personal, family, or household services. Protecting the privacy of nonpublic personal information is of the utmost importance. Nonpublic personal information is information about individuals who are natural persons that is personally identifiable and that was obtained in connection with providing a financial product or service to clients or for marketing purposes.

Company Privacy Policy

This document is the privacy policy for Eclipse Capital Management, Inc. and governs how the Firm will collect, use, maintain and disclose information collected about individuals.

Nonpublic Personally Identifiable Information

The Firm may collect nonpublic personally identifiable information, including but not limited to, name, email address, physical address, phone number, Social Security number, birth date, assets, income, investment experience, current and former employers, positions held, whether they were an investor with the Firm and any account numbers, activity or balances. Information is collected about individuals in a variety of ways, including, but not limited to, managed account agreements and related forms, client transactions, visiting our website, subscribing to our program updates, third party marketing agencies, searches conducted by Firm staff, and direct contact with Firm employees.

Non-personally Identifiable Information

The Firm may collect non-personally identifiable information about individuals through interaction with our website. Non-personally identifiable information may include the browser name, the type of computer used, and technical information about an individual’s means of connection to our website, such as the operating system and the Internet service providers utilized and other similar information. It may also include information on which pages were visited and how the user interacted with the site.

Web Browser Cookies

The Firm website may use "cookies" to enhance the user experience. The user's web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about the user. The user may choose to set their web browser to refuse cookies, or to alert them when cookies are being sent. If they do so, note that some parts of the website may not function properly. Additionally, users will be presented with the option via the website to either opt-in to having tracking information saved, or to opt-out of having tracking information saved. A one-time opt-out cookie will be placed to ensure prospects receive no further requests for permission to save the tracking information when they deny permission. The website may include links to third party websites and the Firm is not responsible for the privacy policies or practices of any third party.

Use of Collected Information

The Firm collects and uses an individual’s information for any one or more of the following reasons:

  • Manage accounts
  • Send periodic emails about the Firm
  • Promote the programs of the Firm
  • Provide customer service
  • Understanding how users utilize the firm website

If an individual provides their email address, it may be used to respond to their inquiries, and/or other requests or questions. If an individual opts-in to our mailing list, they will receive emails that may include company news, program updates, related information, etc. If at any time the individual would like to unsubscribe from receiving future emails, they may contact the Firm at info@ecilpsecap.com to request removal.

Protecting Information

The Firm has adopted appropriate physical and electronic storage and processing practices and security measures in keeping with federal standards to protect against unauthorized access, alteration, disclosure or destruction of nonpublic personal information. Such information is either stored locally on the production servers or in a cloud-based CRM system.

Sharing Nonpublic Personal Information

We do not sell, trade, or rent an individual’s nonpublic personally identifiable information to others. Circumstances where we would share either Nonpublic Personally Identifiable Information or Non-Personally Identifiable Information with an unaffiliated third party would be:

  • Upon request by federal regulatory agencies
  • When audited for information pertaining to non-US clients
  • When required by law
  • Upon request of the individual
  • In connection with the administration, processing, and servicing of client accounts

Data Protections

The firm respects the end user’s rights over their own data and supports the following entitlements:

  • The right to access – Individuals have the right to request the Firm for copies of their personal data.
  • The right to rectification – Individuals have the right to request the Firm correct any information they believe is inaccurate. They also have the right to request the Firm to complete information they believe is incomplete.
  • The right to erasure – Individuals have the right to request the Firm erase their personal data, under certain conditions.
  • The right to restrict processing – Individuals have the right to object to the Firms processing of their personal data, under certain conditions.
  • The right to object to processing – Individuals have the right to object to the Firms processing of their personal data, under certain conditions.
  • The right to data portability – Individuals have the right to request that the Firm transfer data that has been collected to another organization or directly to them, under certain conditions.

If Individuals make a request, all efforts will be made to respond within one month.

Information Retention

The Firm will retain information for business purposes as required.

Privacy Policy Changes

The Firm has the discretion to update this privacy policy at any time. Revisions will be denoted with an updated date at the top of the cover page. In addition, the Firm would inform investors of any such changes as required by law.

Contact

Questions about this policy or requests pertaining to personal data should be addressed to the Information Commissioner at:

Eclipse Capital Management, Inc.
7700 Bonhomme Avenue, Suite 500
St. Louis, MO, 63105
info@eclipsecap.com
(314) 725-2100