If you are a California resident, you have certain rights about the personal data we gather and use about you.1
You have the right to ask us what personal information of yours we collect and why. The information may include the following:
We gather your personal information to provide investment advisory services to you and to provide you with invoices, reports and notifications relating to your account(s) with us and about our firm and our services to you.
You also have the right to request Modera to delete it. We are subject to record retention requirements set forth by our regulator, the United States Securities and Exchange Commission (“SEC”). We retain your personal data in compliance with applicable laws and regulations in the United States, primarily Rule 275.204-2 under the Investment Advisers Act of 1940 (the “Books and Records Rule”). This means we are obligated to keep your personal data for a period of at least five years from the end of the fiscal year during which we last updated the record.
As a matter of practice, we retain your personal data throughout the course of our relationship with you. After the expiration of the period for which the SEC obligates us to retain your data, your personal data will be evaluated for deletion according to our data destruction policy.
You also have the right to contact us regarding the disclosure of your information. Requests can be made by contacting our Chief Compliance Officer Terry Days at (888) 423-7934 or firstname.lastname@example.org.