PRIVACY, TERMS OF USE, SEC RULE 606 & SEC DISCLOSURE

 

OVERVIEW: PRIVACY AND TERMS OF USE

This Privacy Policy and Terms of Use describes the privacy practices for San Francisco Sentry Investment Group, Inc. and its affiliates ("Sentry") and the terms of use governing this website ("Website").  This Privacy Policy and Terms of Use sets out your obligations and ours with respect to your use of the Website and, by using the Website, you agree to abide by the terms of this Privacy Policy and Terms of Use.

We may need to change this policy from time to time in order to address new issues and reflect changes on our Website or in the law.  We will post those changes here so that you will always know what information we gather, how we might use that information, and when we will disclose that information to third parties.  If we make any material changes to this Privacy Policy and Terms of Use, we will post an announcement on the Website.

BY USING THIS WEBSITE, YOU CONSENT TO OUR USING ANY INFORMATION THAT YOU PROVIDE TO US OR THAT WE COLLECT, IN ACCORDANCE WITH THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND TERMS OF USE.


PRIVACY POLICY

As part of our commitment to your privacy, we have written this policy to help you understand what information we gather about you, how we use that information after we’ve gathered it, and when and how we disclose that information. 

INFORMATION WE COLLECT

Sentry collects non-public information (“Information”) about the users of the Website from the following sources: through the submission of a business proposal and other forms or agreements that you submit to us, from requests for information and from correspondence and other communications that you have with us. The Information that we gather may include your name, address, telephone number, email address, social security number, and information about your income level and/or assets. You may also be asked for additional required or optional Information.

We may record certain data about your use of the Website so that we may collect information regarding the number and frequency of visitors to the Website, the websites that users access before and after they visit the Website, the Internet browsers used by our visitors and our visitors’ IP addresses. Such Information is aggregated and will not be tied to you in any personally-identifiable manner other than your IP address. We do not currently use cookies (except to allow access to password-protected portions of the Website) though we may choose to do so in the future.

HOW WE USE YOUR INFORMATION

The Information you provide to us is used for reasonable business purposes and the purpose for which you provided it, including, without limitation, to respond to your request or correspondence. The Information may also be analyzed so that we can serve you in the best manner possible on our Website through new features and functions and to provide you with useful information from Sentry.

We may employ outside agents or third-party service providers to operate the Website and employ others to perform functions on our behalf, such as sending postal mail and e-mail and analyzing data. These third parties have access to personally identifiable information needed to perform their functions. These third parties may not use your Information for any other purpose.

We may disclose your Information to certain third parties if you have requested or authorized the disclosure of the Information, and/or if such disclosure is permitted and/or required by law or to protect the integrity of our services and/or the Website. You hereby authorize us to disclose your Information in those circumstances.

TRANSFER OF INFORMATION TO THIRD PARTIES UPON A CHANGE OF CONTROL

We retain the right to transfer all Information pursuant to a merger or to a purchaser of Sentry or all or substantially all of our assets if that purchaser agrees to abide by the terms of this Privacy Policy and Terms of Use.

HOW YOUR INFORMATION IS PROTECTED

We take reasonable precautions to protect your Information from loss, misuse or alteration. We restrict access to your Information to those employees who need to know that Information to provide products or services to you, and we maintain physical, electronic and procedural safeguards for your Information that comply with federal regulations. You should recognize, however, that there is no such thing as “perfect security” on the Internet.

LINKS TO THIRD PARTY SITES

The Website may contain links to sites owned and operated by other parties. We are not responsible for and have no control over the privacy policies of those sites. We encourage you to review the privacy policies of those sites prior to providing them with any Information.


GENERAL TERMS OF USE

 

NO OFFER OF SECURITIES--DISCLOSURE OF INTERESTS

Under no circumstances should any material at this site be used or considered as an offer to sell or a solicitation of any offer to sell or a solicitation of any offer to buy an interest in any security of Sentry.   Any such offer or solicitation will be made only by means of a Confidential Private Offering Memorandum relating to a particular fund. Access to information about the funds is limited to investors who, among other requirements, either qualify as accredited investors within the meaning of the Securities Act of 1933, as amended, or those investors who generally are sophisticated in financial matters, such that they are capable of evaluating the merits and risks of prospective investments.

OWNERSHIP OF CONTENT

All text, images, graphics, sounds and software code (“Content”) on the Website are copyrighted property of Sentry, its affiliates or others. They may only be used for the personal education of visitors to the Website and they may not be placed in the public domain. You may not reproduce, redistribute, publish or otherwise use by electronic or any other means any of the Content without our prior written consent.

TRADEMARKS

Sentry and other marks indicated on the Website are service marks of Sentry or its affiliates. They may not be used or displayed without the prior written consent of Sentry. All other trademarks, service marks and company names and logos appearing on the Website are the property of their respective owners.

WEBSITE DIRECTED AT UNITED STATES VISITORS

The Website is targeted at and intended for visitors residing in the United States. Given the global nature of the Internet, however, the Website may be accessed by visitors residing outside of the United States. We make no representations or warranties that the Website is appropriate or available for use in countries outside of the United States. Visitors who choose to access the Website from outside of the United States do so at their own initiative and are responsible for compliance with any and all local laws and regulations that may apply to such access.

CHILDREN UNDER 18

Children are not eligible to use our Website. If you are under 18, you can use this Website only in conjunction with your parents or guardians.

LIMITATION OF LIABILITY

Sentry and its affiliates, officers, agents, partners and employees shall not be liable for any direct, indirect, incidental, special or consequential damages, resulting from the use or the inability to use the Website and services or resulting from any information or services obtained or messages received or transactions entered into through the Website or resulting from unauthorized access to or alteration of your transmissions of data, including but not limited to, damages for loss of profits, use, data or other intangible, even if we have been advised of the possibility of such damages. 

Because some jurisdictions do not allow the exclusion or limitation of liability for consequential or incidental damages, in such states liability is limited to the fullest extent permitted by law.

If you are dissatisfied with any portion of the site, or with any of these terms of use, your sole and exclusive remedy is to discontinue using this site.

APPLICABLE LAW

This Privacy Policy and Terms of Use will be governed by and construed in accordance with the laws of the State of California, without regard to any principles of conflicts of law. You agree that any action at law or in equity that arises out of or relates to any use of the Website will be filed only in the state or federal courts located in San Francisco and you hereby consent and submit to the personal jurisdiction of such courts for the purposes of litigating any such action.

HOW YOU CAN UPDATE OR CORRECT YOUR INFORMATION AND CONTACT THE WEBSITE

You can call Sentry at the number provided on our Website or send a message to info@sfsentry.com to update or correct your Information. Please also contact us at info@sfsentry.com if you have any questions or concerns regarding the Website or this Privacy Policy and Terms of Use.

 

SEC RULE 606

San Francisco Sentry Securities, Inc. ("SF Sentry Securities") has prepared this report pursuant to U.S. Securities and Exchange Commission Rule 606 requiring all brokerage firms to make publicly available quarterly reports on their order routing practices.  The report provides information on the routing of "non-directed orders"--any order that the customer has not specifically instructed to be routed to a particular venue for execution.  For these non-directed orders, SF Sentry Securities has selected the execution venue on behalf of its customers.

The report is divided into four sections: one for securities listed on the New York Stock Exchange, one for securities listed on the NASDAQ Stock Market, one for securities listed on the American Exchange or regional exchanges, and one for exchange-listed options.  For each section, this report identifies the venues most often selected by SF Sentry Securities, sets forth the percentage of various types of orders routed to the venues, and discussed the material aspects of SF Sentry Securities relationship with the venues.

 

SEC DISCLOSURE

San Francisco Sentry has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us – If after a significant business disruption you cannot contact us at 415 229-9000 or you cannot contact us through normal means, you should go to our website at www.sfsentry.com. If you cannot access us through either of those means, you should contact our clearing firm for instructions on how it may to enter order and any other trade related issues.

Our Business Continuity Plan – We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption. Our business continuity plan addresses: data back-up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact and regulatory reporting. Our clearing firm backs up our records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments.

Varying Disruptions – Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within 48 hours depending on the severity of the event. In either situation, we plan to continue in business and notify you through our web site, www.sfsentry.com, on how to contact us. For more information – To request a hard copy of our business continuity plan, contact the compliance department at 415 229-9000.