Privacy Policy

Protecting your private information is our priority. This Statement of Privacy applies to www.shepherdstadv.com  and Shepherd Street Advisors LLC and governs data collection and usage. For the purposes of this Privacy Policy, unless otherwise noted, all references to Shepherd Street Advisors LLC include www.shepherdstadv.com and SSA. The SSA website is a Company information site. By using the SSA website, you consent to the data practices described in this statement.

What Does Shepherd Street Advisors LLC (“SSA”) Do with Your Personal Information?
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information.

The types of personal information we collect, and share depend on the product or service you have with us. This information can include:

  • Social Security number and investment experience
  • Account balances and transaction history
  • Assets and income

When you are no longer our customer, we continue to share your information as described in this notice.

Reasons we can share your personal information

Does SSA share?

Can you limit this sharing?

For our everyday business purposes—
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes—
to offer our products and services to you

Yes

No

For joint marketing with other financial companies

No

We do not share

For our affiliates’ everyday business purposes—
information about your transactions and experiences

No

We do not share

For our affiliates’ everyday business purposes—
information about your creditworthiness

No

We do not share

For our affiliates to market to you

No

We do not share

For nonaffiliates to market to you

No

We do not share

How Does SSA Protect My Personal Information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How Does SSA Collect My Personal Information?
We collect your personal information, for example, when you:

  • open an account or seek advice about your investments
  • direct us to buy securities or direct us to sell your securities
  • enter into an investment advisory contract

Why Can’t I Limit All of My Sharing?
Federal law gives you the right to limit only

  • sharing for affiliates’ everyday business purposes—information about your creditworthiness
  • affiliates from using your information to market to you
  • sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

Definitions
Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies.

  • SSA has no affiliates

Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies.

  • SSA does not share with nonaffiliates so they can market to you

Joint marketing: A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

  • SSA does not jointly market

Other Important Information for Vermont, California and Nevada Customers
In response to a Vermont regulation, if we disclose personal information about you to non-affiliated third parties with whom we have joint marketing agreements, we will only disclose your name, address, other contact information, and information about our transactions or experiences with you.

In response to a California law, we automatically treat accounts with California billing addresses as if you do not want to disclose personal information about you to non-affiliated third parties except as permitted by the applicable California law. We will also limit the sharing of personal information about you with our affiliates to comply with all California privacy laws that apply to us. 

Nevada law requires us to disclose that you may request to be placed on our “do not call” list at any time by calling 1-831-759-6300. To obtain further information, contact the Bureau of Consumer Protection, Office of the Nevada Attorney General at 555 E. Washington Ave., Suite 3900, Las Vegas, NV 88101; phone 1-702-486-3132; email BCPINFO@ag.state.nv.us.

Collection of your Personal Information
We do not collect any personal information about you unless you voluntarily provide it to us. To wit, we will use your information for, but not limited to, communicating with you in relation to services and/or products you have requested from us. We also may gather additional personal or non-personal information in the future.

Cookie Policy
A “cookie” is a string of information which assigns you a unique identifier that we store on your computer. Your browser then provides that unique identifier to use each time you submit a query to the Site. We use cookies on the Site to, among other things, keep track of services you have used, record registration information, record your user preferences, keep you logged into the Site, facilitate purchase procedures, and track the pages you visit. Cookies help us understand how the Site is being used and improve your user experience.

SSA may use cookies, web beacons, tracking pixels, and other tracking technologies when you visit our website [www.shepherdstreetadvisors.com], including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”) to help customize the Site and improve your experience.

The following types of cookies may be used when you visit the Site:

Analytics cookies monitor how users reached the Site, and how they interact with and move around once on the Site. These cookies let us know what features on the Site are working the best and what features on the Site can be improved.

Our cookies are “first-party cookies”, and can be either permanent or temporary. These are necessary cookies, without which the Site won’t work properly or be able to provide certain features and functionalities. Some of these may be manually disabled in your browser, but may affect the functionality of the Site.

Personalization cookies are used to recognize repeat visitors to the Site. We use these cookies to record your browsing history, the pages you have visited, and your settings and preferences each time you visit the Site.

Security cookies help identify and prevent security risks. We use these cookies to authenticate users and protect user data from unauthorized parties.

Site management cookies are used to maintain your identity or session on the Site so that you are not logged off unexpectedly, and any information you enter is retained from page to page. These cookies cannot be turned off individually, but you can disable all cookies in your browser.

Third-party cookies may be placed on your computer when you visit the Site by companies that run certain services we offer. These cookies allow the third parties to gather and track certain information about you. These cookies can be manually disabled in your browser.

Control of Cookies
Most browsers are set to accept cookies by default. However, you can remove or reject cookies in your browser’s settings. Please be aware that such action could affect the availability and functionality of the Site.

For more information on how to control cookies, check your browser or device’s settings for how you can control or reject cookies.

Sharing Information with Third Parties
SSA does not sell, rent or lease its customer lists to third parties.

SSA may share data with trusted partners to help perform statistical analysis, send you email, or provide customer support. All such third parties are prohibited from using your personal information except to provide these services to SSA, and they are required to maintain the confidentiality of your information.

SSA may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on SSA or the site; (b) protect and defend the rights or property of SSA; and/or (c) act under exigent circumstances to protect the personal safety of users of SSA, or the public.

Automatically Collected Information
Information about your computer hardware and software may be automatically collected by SSA. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the SSA website.

Links
This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

Security of your Personal Information
SSA secures your personal information from unauthorized access, use, or disclosure. SSA uses the following methods for this purpose:

 –          SSL Protocol

When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.

We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.

Right to Deletion
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your personal information from our records; and
  • Direct any service providers to delete your personal information from their records.

Please note that we may not be able to comply with requests to delete your personal information if it is necessary to:

  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with an existing legal obligation; or
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Children Under Thirteen
SSA does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website.

Changes to this Statement
SSA reserves the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by placing a prominent notice on our site, and/or by updating any privacy information on this page. Your continued use of the Site and/or Services available through this Site after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy.

Contact Information
SSA welcomes your questions or comments regarding this Statement of Privacy. If you believe that SSA has not adhered to this Statement, please contact SSA through our contact form or phone number listed on the homepage.

Shepherd Street Advisors LLC
900 Larkspur Landing Circle, Suite 205
Larkspur, California 94939

Effective as of July 20, 2020