We at TPH Asset Management LP (“TPHAM”) understand and appreciate that our clients are concerned about their privacy and about the confidentiality and security of information that we may obtain from them. This policy describes the steps we have taken to safeguard your information and what client information we may share with others.
INFORMATION ABOUT YOU THAT WE MAY SHARE WITH OTHERS
We collect and share with others the following types of personal information about you:
- Information on your account application or other forms, including your name, address, Social Security number, assets, and income;
- Information about your investments and transactions with us, our affiliates and other financial institutions. This may include specific investments, account balances, and cash deposits and withdrawals; and
- Information we receive from consumer reporting agencies relating to your credit and employment history.
TO WHOM WE SHARE INFORMATION ABOUT YOU
We may share your personal information with our affiliates and certain non-affiliated companies. Our affiliates include Tudor, Pickering, Holt & Co. Securities, Inc., Tudor Pickering Holt & Co Advisors LP, TPH Partners Group LP and Tudor, Pickering, Holt & Co. International, LLP.
WHAT INFORMATION ABOUT YOU DO WE DISCLOSE TO NON-AFFILIATES
We may share your personal information with:
- non-affiliated companies that provide processing, account maintenance and related services in connection with your investments and other transactions handled by us; and
- non-affiliated companies and government agencies only to the extent permitted or required by law, for legal, regulatory or other purposes.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION
We maintain the confidentiality, security and integrity of your personal information by:
- Restricting access to your nonpublic personal information to those employees with a legitimate need for the information;
- Maintaining physical electronic and procedural safeguards that meet or exceed federal and industry standards governing how nonpublic personal information should be stored; and
- Contractually limiting the information sharing ability of non-affiliated companies with whom we share your information.
HOW TO CONTACT US WITH PRIVACY QUESTIONS