March 2024
This notice is provided in accordance with the Securities and Exchange Commission’s rule regarding the privacy of consumer financial information (“Regulation S-P”). To affirm the commitment to the proper handling and safeguarding of client information by Bristlecone Advisors, LLC ("Bristlecone"), we have set forth the following Privacy Principles to protect the privacy of our clients.
INFORMATION WE COLLECT
We believe the confidentiality and protection of client information is one of our fundamental responsibilities. And while information is critical to providing quality service, we recognize that one of our most important assets is our clients’ trust. This makes keeping our client information secure a priority.
Bristlecone must collect certain personally identifiable financial information about its clients to provide financial services and products. The personally identifiable financial information that we gather during the normal course of doing business with you may include:
- Information on applications or other forms.
- Information about your transactions with us, our affiliates, or others.
- Information from a consumer reporting agency.
We have established procedures to maintain the accuracy of client information and to keep such information current and complete. These procedures include responding to requests to correct inaccurate information in a timely manner.
INFORMATION WE DISCLOSE
Our firm limits the use, collection, and retention of client information to what we believe is necessary or useful to conduct our business, provide quality service, and offer products, services, and other opportunities that may be of interest to our clients.
We do not disclose any non-public personal information about current or former clients, except as permitted or required by law, or as necessary to provide services. We may disclose information collected to certain nonaffiliated third parties such as attorneys, accountants and persons assessing our regulatory process. When entering into contractual agreements with nonaffiliated third parties, Bristlecone require they also sign a confidentiality agreement.
CONFIDENTIALITY AND SECURITY
Bristlecone recognizes that a fundamental element of maintaining effective client privacy procedures is to provide reasonable protection against unauthorized access to client information. Therefore, we have established appropriate physical, electronic, and procedural safeguards that comply with federal standards to guard against any unauthorized access to client information. Employee access to certain personally identifiable client information is accessible only to those who need it to provide financial products or services.
All Bristlecone Employees are educated about the importance of maintaining the confidentiality of client information and on these Privacy Principles. Any violation of these Privacy Principles is subject to disciplinary measures.