Privacy Policy

TJIM’s Commitment to Your Privacy

We consider our relationship with our clients our most important asset. We strive to maintain your trust and confidence in our firm, an essential aspect of which is our commitment to protect your personal information to the best of our ability. We believe that all of our clients value their privacy, so we will not disclose your personal information to anyone unless:

• it is required by law,
• at your direction, or
• is necessary to provide you with our services.

Your Privacy is NOT for Sale.

We have not and will not sell your personal information to anyone.

What information do we collect, maintain, and communicate?

TJIM collects and maintains your personal information so we can provide investment management services to you. The types and categories of information we collect and maintain about you include:

• Information we receive from you to open an account (social security number, home and/or work address, cell phone number, and email), to establish that our services are suitable given your situation, requirements, and expectations (income, assets, investment objectives, risk tolerance, investment preferences), or to provide investment advice to you;
• information that we generate to service your account (such as trade tickets and account statements); or
• information that we may receive from third parties with respect to your account (such as trade confirmations from brokerage firms, account statements from custodians, and suitability documentation).

TJIM will not disclose any personal information about you or your account(s) unless one of the following conditions is met:

• We receive your prior written consent;
• we believe the recipient is your authorized representative; or
• we are permitted by law to disclose information to the recipient.

How We Protect Your Personal Information

To fulfill our privacy commitment at TJIM, we have instituted firm-wide practices to safeguard the information that we maintain about you. These practices include:

• Adopting polices and procedures addressing physical, electronic and other safeguards to keep your personal information safe;
• limiting access to personal information to those employees who need it to perform their job duties, and
• requiring third parties that perform services for us to agree by contract to keep your personal information strictly confidential.

Even if you decide to close your account(s) or become an inactive client, we will adhere to the privacy policies and practices described above.

(SEC Regulation S-P, as required by the Gramm-Leach-Bliley Financial Services Act of 1999)