Privacy Policy

Who We Are

Formation Capital, LLC (“Formation”) has filed its registration as an investment adviser and its offices are located in Atlanta, Georgia. At Formation, we are committed to safeguarding your personal and financial information. We recognize the importance of protecting the information that you provide to us in order for us to provide our services and products and that you provide when you visit our website located at www.formationcapital.com. The following information is designed to help you understand Formation’s information collection practices.

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to you how we collect, share, and protect your personal information. Please read this carefully to understand what we do. By providing Formation with your personal or financial information, or by visiting this Website, you are accepting the practices described in this Privacy Policy. If you do not agree to this policy, please do not provide us with personal or financial information or use this Website.

What Information We Collect

The types of personal information we collect and share depend on the product or service you have with us. Formation collects non-public personally identifiable information (“PII”) about you as described in this section.

Formation may collect PII about you from the following sources: (1) information that we receive about you on applications, agreements, or other forms; (2) information that you give us verbally; (3) information about your transactions with us or our affiliates; (4) information that you submit to us in written correspondence, including emails and other electronic communications. Information from these sources generally includes, but is not limited to, information on your personal background, financial situation, financial transactions and account numbers.

We generally record certain usage information, such as the number and frequency of visitors to this Website. This information may include the Internet browser you are using and your Internet Protocol (IP) address. If we use this data at all it will be on an aggregate basis, and we will not disclose to third parties any information that could be used to identify you personally.

Cookies

Cookies are small bits of computer code that we may install on your computer when it accesses our Website. Cookies make your visit to our Website easier and more convenient. We may use cookies for purposes such as to authenticate users, provide tailored content, and to determine whether a visitor is new or has visited the site before.

While most browsers are set to accept cookies by default, Web browsers typically also have features that permit you to refuse cookies or to alert you before accepting them. Your browser manufacturer has information on changing the default setting for your specific browser. Please understand that if you refuse to accept cookies from our Website, you may not be able to use some portions of our Website and services.

Our Website may also use various technologies to collect non-PII when someone visits our Website. For example, as you browse our Website, we may collect information about your visit, but not about you personally. We may monitor statistics such as the number of people that visit our Website, and from which domain our visitors come. We also may use outsourcing programs to assist us in analyzing this data to better tailor our websites and services.

How We Use and Disclose Your Information

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the information Formation chooses to share; and whether you can limit this sharing.

We use your PII only to: (1) provide and service our products and services; (2) provide information to our affiliates and Service Providers; and (3) fulfill our legal obligations to any regulatory or government body to whom we are required to report, or to fulfill certain obligations pursuant to the USA Patriot Act. We will not sell, share, or rent your PII to non-affiliated third parties or to affiliated parties for marketing purposes in contravention of this Privacy Policy.

In the course of providing our services, we may disclose PII to non-affiliated companies that perform services for us (“Service Providers”), such as companies that provide transaction processing, or performance reports and statements for assets under management. These Service Providers, however, act on our behalf and are contractually obligated to keep the information we provide them confidential and to use the information only for the purposes authorized.

We also may disclose PII to non-affiliated third parties for other purposes required or permitted by law or regulation. Such disclosures may include: (1) to comply with a court order, legal process, or other judicial or investigative proceeding that produces a request for information from us; (2) to permit auditing of account information; (3) to fulfill or respond to a request from you or your authorized representative; (4) to protect against fraud or as otherwise permitted or required by law, including to protect our legal interest; (5) to acquire, sell or transfer the funds or our business or assets; and (6) as otherwise indicated in this Privacy Policy.

How How We Protect Your Information

To protect personal information for you from unauthorized access or use, we permit access only to Formation employees and our Service Providers’ employees who have a need to know. In addition, we have implemented, and we maintain, technical, administrative, personnel and physical security safeguards.

How Changes to This Privacy Policy

Formation reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. Such changes shall be effective immediately upon posting. We suggest that you visit the Website and review the Privacy Policy periodically for changes. You acknowledge that by accessing our Website after we have posted changes to this Privacy Policy, you are agreeing to the terms of the Privacy Policy as modified.

Access, Correction and Questions

If you have any questions as to this Privacy Policy, or wish to notify us of any errors or changes as to any PII you provide to Formation, you can contact Nela Powell, Chief Compliance Officer, at npowell@formationcapital.com or compliance@formationcapital.com.