September 13, 2012

Privacy Policy

When you invest with Delta Investment Management, you share your nonpublic personal and financial information with us. We understand you are entrusting us to protect this information. We collect only the information necessary to provide you with the investment advisory services for which you hired us. This information is shared only with select business partners associated with the delivery of our products and services. These companies are not authorized to use or share the information for any purpose other than to help us serve you. We do not sell this information to any third party. If you have any questions about our privacy policy please call (415) 249-6337 or email us at info@deltaim.com, and we will be happy to assist you. Our policy is to limit how, and with whom, we will share information.

We do not share information about you, or our former clients, with our affiliates or service providers or other third parties except on the limited basis permitted by law. It is necessary for us to have your personal information so that we know how to contact you in order to answer questions, or to respond to your requests for information from us.

We do not sell lists of our clients, nor do we disclose client information to marketing companies. We do not share information with other companies. The exception being those companies hired to provide specific services for us.

We collect only the information necessary to deliver our products and services.

We may collect nonpublic personal information about you that generally falls into one of the following categories:

  • Information, such as your address, Social Security number, date of birth, phone number, income, investable assets, and investment profile, that you may provide on account applications or during your business relationship with us.
  • Account information, such as your investment choices, account balances and transaction history.

How we use the information we collect.

We use the information we collect primarily to maintain your accounts and process your transactions and requests. When required by law, we may need to disclose personal information where such action is deemed necessary to comply with a current judicial proceeding, court order or legal process served on the firm. We may also rely on the information you provided to help us better understand you and your investing needs. This allows us to offer relevant investment products and services that may be of interest to you, and to help us with our research efforts, mailings, or other Delta marketing or communications activities. Procedures to protect confidentiality and security of our clients.

While no company can guarantee the security of your information, we take steps to protect information from unauthorized access, including reasonable administrative, physical, and technical safeguards designed to protect information about you. We also apply special measures for authentication of information you request or submit to us on our website, www.deltaim.com. Internally, we limit access to nonpublic personal and financial information about you to those Delta personnel who need to know the information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal and financial information. Additionally, we conduct periodic reviews of our computer systems, including security features. How you may obtain Proxy Voting information.

Information on Delta’s Proxy Voting Policies & Procedures may be obtained by visiting our website at www,deltaim.com, or by contacting our office at (415) 249-6336 or email us at info@deltaim.com.

A special note to Newsletter Subscribers:

Nick Atkeson and Andrew Houghton write the commentary for various newsletters that are published and owned by Traders Reserve, LLC (“TR”), a company not affiliated with Delta Investment Managment, LLC.  Delta Investment Management, LLC have any control over information you may provide to TR. If you would like any information about that you provided to TR, to remain private, please contact TR directly at (800) 863-7650.

How you can correct and update personal information.

If you need to update or correct any personal information, you may contact us at (415) 249-6337 or email us at info@deltaim.com.

Offer to receive a current copy of our ADV Part II.

This serves as notification of SEC Rule 204-2 (a) (14) which states that all investment advisers must make available on an annual basis, to all existing clients, a copy of Form ADV Part II.  If you would like to receive a free copy of our most current Form ADV Part II, please call us at (415) 249-6337, or write to us at:

Delta Investment Management / ADV Part II
Attn: Client Services
One California Street, Suite 2800
San Francisco, CA 94111

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