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Lumina Investment Advisors, LLC views protecting private information regarding its clients and potential clients as a top priority. Pursuant to the requirements of the Gramm-Leach-Bliley Act (the”GLBA”) and guidelines established by the Securities Exchange Commission regarding the Privacy of Consumer Financial Information (Regulation S-P), the Company has instituted the following policies and procedures in an effort to ensure that such nonpublic private information is kept private and secure. This policy also outlines what the Company and its associated persons are allowed to use the confidential personal information collected in connection with its advisory activities.
Regulation S-P defines “consumer” as an individual who obtains or has obtained a financial product or service from a financial institution primarily for personal, family, or household purposes, or for that individual’s legal representative. Generally, an individual is a consumer if he or she provides nonpublic information to the Company in connection with obtaining or seeking to obtain investment advisory services, whether or not the Company provides such services to the individual or establishes a continuing relationship with the individual.
“Customer” is defined as a consumer who has an on-going relationship with the institution. Generally, a customer is a consumer who has an investment advisory contract with the Company (whether written or oral) and/or the Company regularly effects or engages in securities transactions with or for a consumer even though the Company does not hold assets of the consumer.
While these terms have specific definitions, for the purposes of the Company’s policies, both consumers and customers will be collectively referred to as “clients” (or “potential clients” or “former clients” where applicable).
This policy serves as formal documentation of the Company’s ongoing commitment to the privacy of its clients. All Associated Persons will be expected to read, understand, and abide by this policy, as well as to follow all related procedures to uphold the standards of privacy and security set forth by the Company. This Policy, and the related procedures contained herein, is designed to comply with applicable privacy laws, including the GLBA, and to protect nonpublic personal information of the Company’s clients.
The Company is aware that some states impose more specific requirements for safeguarding personal information against unauthorized disclosure and for responding to information security breaches. In the event the firm registers in such jurisdictions with strict privacy-related laws or regulations affecting the information practices of the Company, this Privacy Policy will be revised as necessary and any changes will be disseminated and explained to all personnel.
This Privacy Policy covers the practices of the Company and applies to all nonpublic personally identifiable information, including information contained in consumer reports, of our current and former clients.
In Regulation S-P, the Securities and Exchange Commission (the “SEC”) published guidelines, pursuant to section 501(b) of the GLBA, that address the steps a financial institution should take in order to protect client information. The overall security standards that must be upheld are:
The Company limits the use, collection, and retention of client or potential client information to what we believe is necessary or useful to conduct our business or to offer quality products, services, and other opportunities that may be of interest to our clients or potential clients.
The Company collects nonpublic personal information about clients and/or potential clients from various sources. These sources and examples of types of information collected include:
The Company has a “do not share” policy. We do not disclose nonpublic personal information to nonaffiliated third parties, except under one of the GLBA privacy exceptions, as described below. Since the Company currently operates under a “do not share” policy, it does not need to provide the right for its clients to opt out of sharing with nonaffiliated third parties, as long as such entities are exempted as described below. If our information sharing practices change in the future, we will implement opt out policies and procedures, and we will make appropriate disclosures to our clients.
In certain circumstances, Regulation S-P permits the Company to share nonpublic personal information about its clients with nonaffiliated third parties without providing an opportunity for those individuals to opt out. These circumstances include sharing information with a non-affiliate (1) as necessary to effect, administer, or enforce a transaction that a client requests or authorizes; (2) in connection with processing or servicing a financial product or a service a client authorizes; and (3) in connection with maintaining or servicing a client account with the Company.
Service Providers – From time to time, the Company may have relationships with nonaffiliated third parties (such as attorneys, auditors, accountants, brokers, custodians, and other consultants), who, in the ordinary course of providing their services to us, may require access to information containing nonpublic information. These third-party service providers are necessary for us to provide our investment advisory services. When we are not comfortable that service providers (e.g., attorneys, auditors, and other financial institutions) are already bound by duties of confidentiality, we require assurances from those service providers that they will maintain the confidentiality of nonpublic information they obtain from or through us. In addition, we select and retain service providers that we believe are capable of maintaining appropriate safeguards for nonpublic information, and we will require contractual agreements from our service providers that they will implement and maintain such safeguards.
Processing and Servicing Transactions – The Company may also share information when it is necessary to effect, administer, or enforce a transaction requested or authorized by clients. In this context, “necessary to affect, administer, or enforce a transaction”: includes what is required or is a usual, appropriate, or acceptable method:
Sharing as Permitted or Required by Law. The Company may disclose information to nonaffiliated third parties as required or allowed by law. For example, this may include disclosures in connection with a subpoena or similar legal process, a fraud investigation, recording of deeds of trust and mortgages in public records, an audit, or examination, or the sale of an account to another financial institution.
By understanding how the Company shares data with its clients, their agents, service providers, parties related to transactions in the ordinary course of business, or joint marketers, the Company endeavors to ensure that client data is shared only within the exceptions noted above.
The Company has developed a Privacy Notice, as required under Regulation S-P, to be delivered to clients initially and to current clients on an annual basis. The notice discloses the Company’s information collection and sharing practices and other required information. The notice will be revised as necessary any time information practices change. A copy of the Company’s Privacy Notice is included as Appendix D.
1. Initial Privacy Notice – As regulations require, all new clients receive an initial Privacy Notice at the time the client relationship is established (i.e., upon execution of the agreement for services).
2. Annual Privacy Notice – The GLBA regulations require that disclosure of the Privacy Policy be provided to existing clients on an annual basis. The Company will deliver its annual Privacy Notice in conjunction with the annual offer of its ADV Part 2.
Regulation S-P requires that the Company amend its Privacy Policy and promptly distribute a revised disclosure to clients, if there is a change in the Company’s collection, sharing, or security practices.
If two or more individuals jointly obtain a financial product or service from the Company, the Company may satisfy the initial, annual, and revised notice requirements by providing one notice to those individuals jointly.
Safeguarding of Client Records and Information
The Company has implemented internal controls and procedures designed to maintain accurate records concerning client personal information. The Company’s clients have the right to contact the Company if they believe that Company records contain inaccurate, incomplete, or stale information about them. The Company will respond in a timely manner to requests to correct information.
To protect client and personal information, including consumer report information, the Company maintains the following security measures and safeguards for the storage of, access to, and disposal of client personal information, including consumer report information, obtained and/or maintained in hard copy and/or electronically, as well as access and protections of its computer and information systems:
Lumina provides wealth management, investment and family office services to help each client determine and achieve their financial goals. We are a team of professionals highly qualified in all financial areas in order to find the best solution that adapts to your needs.
LUMINA INVESTMENT ADVISORS LLC – Investment Adviser Firm (sec.gov)
