Notice of Our Privacy Policy

Protecting the privacy and security of our clients’ confidential information is important to us. This notice describes practices and policies through which we maintain the confidentiality and protect the security of your non-public personal information.

What Information We Collect

While providing services to you we may collect the following types of “non-public personal information” about you:

• Information we receive from you or your financial advisor on applications or other forms or statements, or by electronic means or telephone, which may include such items as your name, address, social security number, assets, income, types and amounts of your investments and other financial, brokerage and bank account information, and
• Information about your transactions with us, our affiliates and others, as well as other account data. We may also receive information from other firms, such as those from which you transfer assets to your current custodian or to which you subsequently transfer assets.

“Non-public personal information” is non-public information about you that we obtain in connection with providing a financial product or service to you, such as the information described in the above examples.

“Affiliates” include companies related to Oak Ridge Investments, LLC through common control or ownership.

What Information We Disclose

We do not disclose non-public information about you or our other clients to non-affiliated third parties, except as permitted or required by law. We do not sell any personal information about our clients to third parties. We are permitted by law to share any of the information we collect, as described above, with our affiliates and we may share that information with our affiliates. In addition, in the normal course of serving clients, information we collect may be shared with companies that perform various services for us and/or our clients such as transfer agents, data-system service and/or back-up providers, auditors, attorneys and client custodian(s), consultant(s) and/or broker-dealer(s). These companies are to use this information only for the services for which we or you hired them and as allowed by applicable law.

Confidentiality and Security Procedures

To protect your personal information, we do not permit access to your information by our service providers or to our employees, if any, who do not need to have such access to provide products or services to you or to manage, administer or service your account or account records for you or for us. We maintain physical, electronic and procedural safeguards to protect the confidentiality, integrity and security of your non-public personal information. Our employees are instructed to keep clients’ personal and financial information confidential and not to disclose it to unauthorized persons, either during their employment with Oak Ridge or afterward. We do not collect non-public personal information about our clients on our website.

We will continue adhering to the privacy policies and practices in this notice after your account is closed or becomes inactive.