Privacy Policy

Client Privacy Policy Notification (Updated as of July 2011)

Pacific Global Investment Management Company (referred to as “we,” “our,” or “us,” throughout this notice) respects our clients’ right to privacy and is committed to safeguarding information provided to us.  Our privacy policy reflects our commitment to maintaining the privacy of our clients’ confidential information. We appreciate the confidence clients have shown by entrusting us with their investments.  We do not sell non-public personal information to anyone and only share it as described in this Policy.

Personal information we collect

We also know that clients expect us to service their accounts and process their requests in an accurate and efficient manner.  To do so, we must collect and maintain certain personal information about clients, including, but not limited to:

  • information from applications and forms we receive from clients and from their transactions with us or the custodian of their account, such as their name, address and social security number;
  • an address we receive from a third party when they have moved;
  • information, such as account balances and investment transactions with us; and
  • information (commonly referred to as “cookies”) collected from the Web browser of their computer that allows our website to recognize their browser.

We also may collect and maintain certain personal information about attorneys-in-fact and others whom our clients have authorized to act with respect to their accounts (“Authorized Representatives”).  We treat such Authorized Representative’s personal information under our Policy in a similar manner to the way we treat each client’s personal information.

Personal information we may disclose

To service clients’ accounts and process their requests, we may share non-public personal information with our affiliates and service providers.  We will only share non-public personal information with outside parties in the limited circumstances permitted by law.   Our service providers are not permitted to use clients’ personal information for any purpose other than servicing their accounts or as permitted by law.

If a client has designated a solicitor, he or she will receive copies of confirmations, account statements or other documents on the account.

Confidentiality and Security

To protect clients’ personal information, and the information of any client’s Authorized Representatives, we permit access to the personal information of each client and the personal information of each Authorized Representative only to authorized employees who need to know the information to provide products and services.  Our employees are required to follow procedures with respect to maintaining the confidentiality of non-public personal information.

We maintain physical, electronic and procedural safeguards to protect the information.  We use technological means (such as backup files, virus detection and eradication software, firewalls, and other computer software and hardware) to protect against unauthorized access or alterations to client data.  A firewall is a combination of hardware and software that controls the information that can enter computers from the Internet. Firewalls utilize rules which are intended to defend against intruders and viruses. We continually monitor our systems for evidence of attempted security breaches and regularly review industry standards for security to make sure that we are using current technologies. Also, we perform ongoing evaluations of our systems containing client information and make upgrades to these systems as appropriate.


This Policy is effective as of July 12, 2011 and is subject to change.  Material changes to the Policy will be posted on our website, included in account statements and updated on Part 2A of our Form ADV.

For more information

Clients may contact Client Services at (800) 404-6693 between 7 a.m. and 5 p.m. Pacific Time, Monday through Friday to update account information as well as information about any of our services.

Pacific Global Investment Management Company Website Privacy Policy

Your email address.  We collect your email address as well as other information you may provide (such as your name and telephone number) when you email us from the Contact Us page on our website.  No information that we receive through the website will be given to third parties. The personal information will be used only to provide the information you requested. Other non-personal information, such as information about your computer connection, IP address, and information about the pages you visit on the website, will be used only to improve our service to you. For example, this information can enable us to adjust our website to improve the information provided or to research technical problems.

The Pacific Global Investment Management Company website is a proprietary website. While we strive to protect all information we receive when you visit our website, we cannot guarantee the security of any information you transmit to us online; therefore, you do so at your own risk.