Privacy Policy

PRIVACY POLICY NOTICE

The Firm’s Privacy Policy sets forth the manner in which Felix Investments LLC (the “Firm”) may collect, utilize and maintain nonpublic personal information about customers, as required under federal and other applicable law. The Firm is committed to protecting privacy and maintaining the confidentiality and security of a customer’s personal information. As noted above, the Privacy Policy only applies to products and services provided by the Firm to individuals and which are used for personal, family, or household purposes (not business purposes).

Collection of Investor Information

The Firm may collect personal information about customers from the following sources:

  1. 1.Customer questionnaires and other information provided by the customer in writing, in person, by telephone, electronically or by any other means. This information may include name, address, employment information, and financial and investment qualifications, as applicable;
  2. 2.Information about customers from financial institutions and service providers with whom a customer may have authorized to provide such information to the Firm;
  3. 3.Transactions in a customer’s account, including account balances, investments, contributions and withdrawals; and
  4. 4.Verification services and consumer reporting agencies, including a customer’s creditworthiness or credit history, as applicable.

Disclosure of Nonpublic Personal Information

The Firm does not disclose nonpublic personal information about customers or potential customers to affiliates or nonaffiliated third parties except as permitted by law. For example, the Firm may share nonpublic personal information about investors, without the investor’s consent, with affiliated and nonaffiliated parties in the following situations, among others:

  1. 1.In connection with the administration and operations of the Firm and other of the Firm’s products and services, with the Firm’s brokers, attorneys, accountants, auditors, administrators or other service providers;
  2. 2.To respond to a subpoena or court order, judicial process or regulatory inquiry;
  3. 3.In connection with a proposed or actual sale, merger, or transfer of all or a portion of its business;
  4. 4.To protect or defend against fraud, unauthorized transactions (such as money laundering), law suits, claims or other liabilities;
  5. 5.To respond to requests for information regarding compliance with anti-money laundering laws;
  6. 6.Upon consent of a customer to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the investor; and
  7. 7.To assist the Firm in offering affiliated products and services to investors.

As indicated above, the foregoing may include responses to inquiries for purposes of compliance with anti-money laundering and anti-terrorist due diligence, disclosure or reporting requirements. The Firm also may share nonpublic personal information about customers at customer direction or with customer consent.

Former and Prospective Investors

The same Privacy Policy applies to former and prospective customers.

Protection of Subscriber Information

The Firm maintains physical, electronic and procedural safeguards that comply with federal standards to protect investor information. The Firm restricts access to the personal and account information of investors to those employees who need to know that information in the course of their job responsibilities.

Further Information

The Firm reserves the right to change its Privacy Policy at any time. The examples contained within this Policy are illustrations and are not intended to be exclusive. The Firm’s Privacy Policy complies with federal law regarding privacy. Investors may have additional rights under other foreign or domestic laws that may apply.

Why Felix?

Our reputation is based on our experience, the integrity of our people, and the equality of our work- not as we measure it, but as our clients do. Our passion is building relationships that build value for our clients, their shareholders and customers, and the communities that they serve.