Symmetry® Partners, LLC
Client Personal Information Privacy Principles


We want to assure all of our clients that the safeguarding of client’s personal information is an issue we take
seriously at Symmetry Partners, LLC and affiliates (“Symmetry”). To affirm our continuing commitment to our
proper use of client’s personal information, we have adopted the following Privacy Principles. It is these Privacy
Principles that guide us in safeguarding our client’s personal information. Please read these Privacy Principles
carefully before sharing with us any personal information described below. When you provide us with
personally identifiable information, you are acknowledging that the information will be subject to the terms of
this Privacy Policy.


1. Recognition of a Client’s Expectation of Privacy: At Symmetry we believe the confidentiality and
protection of client’s personal 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. Thus, the safekeeping of client personal information is a priority for Symmetry.


2. Use, Collection, and Retention of Client Personal Information: Symmetry limits the use, collection, and
retention of client personal 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. Information collected may include, but is not limited to: name, address, telephone number, email
address, tax identification number, date of birth, bank account, brokerage account, employment status,
annual income and net worth. The client personal information is provided to us by clients who choose to
engage us to perform services on their behalf.


3. Maintenance of Accurate Information: Symmetry recognizes that it must maintain accurate client
records. Therefore, Symmetry has established procedures to maintain the accuracy of client personal
information and to keep such information current and complete. These procedures may include asking
clients to respond to requests to correct inaccurate information in a timely manner.


4. Limiting Employee Access to Personal Information: Symmetry has restrictions in place to limit
employee access to client personal information. Employees are educated on the importance of maintaining
the confidentiality of client personal information and to comply with these Privacy Principles. Because of
the importance of these issues, all Symmetry employees are responsible for maintaining the confidentiality
of client personal information and employees who violate these Privacy Principles will be subject to
disciplinary measures.


5. Protection of Client Personal Information via Established Security Procedures: Symmetry
recognizes that a fundamental element of maintaining effective procedures regarding the safeguarding of
client personal information is to provide reasonable protection against the unauthorized access to client
personal information. Therefore, Symmetry has adopted appropriate administrative, physical, and
technological security standards and procedures to guard against any unauthorized access to client
personal information. In addition, Symmetry has policies, procedures, and internal controls in place that
are reasonably designed to comply with all laws and regulations of the Securities and Exchange
Commission; 17 CFR Part 248 Red Flags Identity Theft Program for client’s protection.

 

6. Restrictions on the Disclosure of Client Personal Information:
a. When it comes to sharing client personal information with affiliated or unaffiliated parties, Symmetry
places strict limits on who receives specific client personal information and such sharing is done in
accordance with Section 8, 11 and this Section 6(a).

 

We share the minimum amount of information necessary for that firm to offer its product or service.

We may share client personal information with affiliated or unaffiliated third parties that assist us

inproviding our products and services to our clients; disclosures made in the course of

processing authorized transactions and servicing accounts; in the normal course of our business;

made at thedirection or with consent of the client; to protect against actual or potential fraud; to persons

who areassessing the firm’s compliance risk and with the firm’s attorneys, accountants, auditors and advisers;
in connection with acquisition and sales; to assert legal rights or defense against legal claims; to
comply with applicable laws or regulations; and to comply with a valid legal process such as a search
warrant, subpoena or court order, and/or to investigate suspected fraud.


b. With the exception of those situations outlined in 6(a), 8 and 11, Symmetry does not share client
personal information with unaffiliated third parties. If Symmetry receives a request for such client
personal information that goes beyond the scope of the items listed in 6(a), then it is Symmetry’s
policy to contact the client for permission. The client can decline and opt out at this time.


7. Maintaining Client Privacy in Business Relationships with Affiliated or Unaffiliated Third Parties: If
we provide client personal information to an affiliated or unaffiliated third party with which we have a
business relationship, we will provide to the third party only on the condition that the third party keep such
information confidential, consistent with the conduct of our business relationship.


8. Consumer Report Information: The nature of our business seldom requires the firm to handle consumer
report information. However, when applicable, Symmetry shall take reasonable measures, when disposing
of consumer report information, to protect against unauthorized access or use of such information.
Symmetry shall ensure that consumer report information shall only be provided to necessary service
providers who can properly dispose of such information.


9. Non-Personally Identifiable Information: In addition to client personal information, we may collect

non-personally identifiable information, such as what type of browser used or information about a computer or
IP address. We may then link this non-personally identifiable information for any number of reasons,
including, but not limited to, working with business partners and promoting and improving our business,
products or services.


10. Information over the Internet: Client personal information may be accessed and transferred over the
Internet and Symmetry does not operate or control the internet and that: (i) viruses, worms, trojan horses,
or other undesirable data or software; or (ii) unauthorized users (e.g., hackers) may attempt to obtain
access to and damage client personal information, or Site, computers, or networks.


11. Sale of Business: Information about our clients might be disclosed as part of any merger, acquisition,
debt financing, sale of company assets, as well as in the event of insolvency, bankruptcy, or receivership
in which client personal information could be transferred to third parties as one of the business assets of
the company.


12. Disclosure of Privacy Principles to Clients: Symmetry recognizes and respects the privacy
expectations of our clients. We want our clients to understand our commitment to privacy in our use of
client information. As a result of our commitment, we have developed these Privacy Principles, which are
made readily available to our clients. Clients who have questions about these Privacy Principles or have a
question about the privacy of their client information should call Symmetry Compliance 800-786-3309 or email
symmetrycompliance@symmetrypartners.com.


These Privacy Principles apply to individuals, and we reserve the right to change these Privacy Principles, and
any of the policies or procedures described above, at any time without prior notice. These Privacy Principles
are for general guidance and do not constitute a contract or create legal rights and do not modify, supersede or
amend any written agreements we have with our clients.