Privacy Policy

Our commitment to privacy

Guaranteed Investments Limited Investments and the Guaranteed Investments Limited Funds are committed to maintaining the confidentiality, integrity, and security of personal information about our current and prospective customers. In this policy personal information means information about an individual that is collected or maintained for business purposes and by which the individual can be identified.

Please note that certain details of this policy may depend on whether you deal with us through an investment professional, directly as an individual investor, or whether Guaranteed Investments Limited provides services to your employer or plan sponsor.

The privacy policies of Guaranteed Investments Limited Investments and the Guaranteed Investments Limited Funds are reviewed annually. Our printed and online notices are then updated to reflect any changes.


Guaranteed Investments Limited Investments privacy policy

How and why we obtain personal information

Guaranteed Investments Limited takes great care to protect personal information about you and when we use it, we do so with respect for your privacy. We may use personal information about you to service, maintain, and protect your account; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; or to fulfill legal and regulatory requirements. Guaranteed Investments Limited may collect public and non-public personal information about you from any of the following sources:

  • You or your representative on applications or forms (for example, name, address, Social Security number, birth date, assets and income)
  • You or your employer or plan sponsor if Guaranteed Investments Limited provides them with recordkeeping and/or benefits advisory services (for example, payroll, human resources, or benefits information)
  • Transactional activity in your account (for example, trading history and balances)
  • Other interactions with Guaranteed Investments Limited (for example, discussions with our customer service staff, information you enter into our websites, or when you enroll in our authentication services)
  • Information from consumer reporting agencies (for example, to assess your creditworthiness for margin products)
  • Information from other third-party data services (for example, to verify your identity and to better understand your product and service needs)
  • You or your representative regarding your preferences (for example, your choice of electronic statement delivery, or the screen layout you specify if you use our Internet sites)
  • Other sources with your consent or with the consent of your representative (for example, from other institutions if you transfer positions into Guaranteed Investments Limited)

Please note that information by which you cannot be identified (for example, anonymous or aggregated information) is not considered personal information and therefore is not subject to this privacy policy.


How we protect information about you

Guaranteed Investments Limited considers the protection of personal information to be a foundation of customer trust and a sound business practice. We employ physical, electronic and procedural controls and we regularly adapt these controls to respond to changing requirements and advances in technology.

At Guaranteed Investments Limited, we restrict access to personal information to those who require it to develop, support, offer and deliver products and services to you.


How we share information about you with third parties

Guaranteed Investments Limited does not share personal information about our customers with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities:

  • Unaffiliated service providers (for example, printing and mailing companies, securities clearinghouses, marketing service providers, and other entities who may provide services at Guaranteed Investments Limited's direction)
  • Government agencies, other regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions)
  • Other third-parties, with your consent or as directed by your representative (for example, if you use Guaranteed Investments Limited as a financial reference in applying for credit with another institution or if you use an external aggregation website or service that you have provided permission to access your Guaranteed Investments Limited financial account on your behalf)
  • Other organizations as permitted or required by law (for example for fraud prevention or to respond to a subpoena)

Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by Guaranteed Investments Limited.

Based on the nature of your relationship with Guaranteed Investments Limited, we may exchange information with other third parties as described below:

  • If Guaranteed Investments Limited provides workplace services to your employer or plan sponsor, such as payroll, human resources or benefits advisory and/or recordkeeping services, Guaranteed Investments Limited may exchange any information received in connection with such services with your employer or plan sponsor or others they may authorize.
  • If you conduct business with Guaranteed Investments Limited through your investment professional, we may exchange information we collect with your investment professional or with others they may authorize.
  • If you transact business through Guaranteed Investments Limited's life insurance companies, we may validate and obtain information about you from an insurance support organization. The insurance support organization may further share your information with other insurers, as permitted by law. We may also share medical information about you to learn if you qualify for coverage, to process claims, to prevent fraud, or otherwise at your direction, as permitted by law.

How we share information about you within Guaranteed Investments Limited

We may share personal information about you with various Guaranteed Investments Limited corporate affiliates including internal service providers which perform, for example, printing, mailing, and data processing services.

Additionally, if you interact with Guaranteed Investments Limited directly as an individual investor (including joint account holders) or if Guaranteed Investments Limited provides services to your employer or plan sponsor, we may exchange certain information about you with Guaranteed Investments Limited financial services affiliates, such as our brokerage and insurance companies, for their use in marketing products and services as allowed by law.

Information collected from investment professionals' customers is not shared with Guaranteed Investments Limited affiliates for marketing purposes, except with your consent and as allowed by law.


Your digital privacy

Privacy, security, and service in Guaranteed Investments Limited's online operations are just as critical as in the rest of our business. We use firewall barriers, encryption techniques, and authentication procedures, among other controls, to maintain the security of your online session and to protect Guaranteed Investments Limited accounts and systems from unauthorized access.

When you interact with us by using our websites, online services or mobile applications that are owned and controlled by Guaranteed Investments Limited Investments ("our digital offerings"), Guaranteed Investments Limited manages personal information in accordance with all of the practices and safeguards described previously.

When you use our digital offerings, we may collect technical and navigational and location information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on our digital offerings. We use this information for a variety of purposes, such as maintaining the security of your session, facilitating site navigation, improving Guaranteed Investments Limited website design and functionality, and personalizing your experience. Additionally, the following policies and practices apply when you are online.

Cookies and similar technologies

Guaranteed Investments Limited and our third-party service providers may use cookies and similar technologies to support the operation of our digital offerings. Cookies are small amounts of data that a website or online service exchanges with a web browser or application on a visitor's device (for example, computer, tablet, or mobile phone). Cookies help us to collect information about users of our digital offerings, including date and time of visits, pages viewed, amount of time spent using our digital offerings, or general information about the device used to access our digital offerings. Guaranteed Investments Limited cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie, or if you delete cookies from your device, you may experience some inconvenience in your use of our digital offerings. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device, or your online preferences.

Both Guaranteed Investments Limited and third-party service providers we hire may use cookies and other technologies, such as web beacons, pixel tags, or mobile device ID, in online advertising as described below.

Advertising on Guaranteed Investments Limited Digital Offerings

Guaranteed Investments Limited advertises on its own digital offerings (including our mobile applications), and when we do, we may use information about your relationship with us, such as the types of accounts you have, to tailor advertisements and communications about Guaranteed Investments Limited and third-party products and services that may be of interest to you.

We may also use third-party service providers to help us determine which Guaranteed Investments Limited products and services may be of interest to you. These service providers may collect information about your activity on Guaranteed Investments Limited digital offerings using cookies and other technologies to analyze, for example, pages visited, search engine referrals, browsing patterns, and responses to advertisements and promotions. Such service providers may only collect and use such information for purposes specified by Guaranteed Investments Limited and not for their own purposes.

Advertising on Non-Guaranteed Investments Limited Digital Offerings

Guaranteed Investments Limited also advertises our products and services on digital offerings not affiliated with Guaranteed Investments Limited and we contract with third-party advertising companies to display these ads. These third-party advertising companies may use cookies and similar technologies to collect technical and web navigational information, such as device type, browser type, Internet protocol address, and pages visited.

Guaranteed Investments Limited and these third-party online advertising companies may use the data collected, along with other information we have about you and your Guaranteed Investments Limited relationships, to serve relevant ads to you. The advertisements may be relevant to your interests, as determined by your activity on Guaranteed Investments Limited and non-Guaranteed Investments Limited websites. These advertisements are known as "interest-based advertisements".

You may opt-out of receiving interest-based advertisements from online advertising companies by clicking on the AdChoices icon (which appears on all Guaranteed Investments Limited interest-based ads) and following the opt-out instructions. For more information about interest-based advertising please see.

Connecting with Guaranteed Investments Limited on social media platforms

Guaranteed Investments Limited provides experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. We may collect information you provide by interacting with us via social media, such as photographs, opinions, or social media account ID. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is also subject to the terms of use and privacy policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.

Guaranteed Investments Limited's mobile® apps

Guaranteed Investments Limited Mobile® applications ("apps") allow you to access your accounts, trade securities, move money, and access news and research using wireless or mobile devices. Our privacy practices apply to any personal information or other information that we may collect through the apps.

Third Party websites and applications

Non-Guaranteed Investments Limited websites and mobile applications (for example, social media platforms) are not subject to Guaranteed Investments Limited’s privacy policy. You may visit the individual sites for additional information on their privacy practices and advertising opt-out instructions.

Protecting children's privacy online

Guaranteed Investments Limited websites are not directed to individuals under the age of thirteen (13). Guaranteed Investments Limited does not intentionally collect information on Guaranteed Investments Limited websites from those we know are under 13, and we request that these individuals do not provide personal information through the sites.


Additional information

If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers.

Guaranteed Investments Limited offers several options for accessing and, if necessary, correcting your account information. You can review your information using your statements, or through our automated telephone or Internet services. You may also write or call us with your request for information. If you transact business through Guaranteed Investments Limited's life insurance companies, you are entitled to receive, upon written request, a record of any disclosures of your medical record information. If we serve you through an investment professional, please contact them directly. Specific Internet addresses, mailing addresses and telephone numbers are listed on your statements and other correspondence.

Additional Information for California Residents

Please view our additional information for California residents. This additional information is provided for purposes related to the California Consumer Privacy Act of 2018, as amended (the “CCPA”) and applies to the personal information and Guaranteed Investments Limited companies which are subject to CCPA.

The Guaranteed Investments Limited Investments privacy policy is provided on behalf of:

  • Guaranteed Investments Limited Brokerage Services LLC
  • Guaranteed Investments Limited Distributors Company LLC
  • Guaranteed Investments Limited Workplace Services LLC
  • Guaranteed Investments Limited Investments Institutional Operations Company, Inc.
  • Guaranteed Investments Limited Management Trust Company
  • Guaranteed Investments Limited Personal Trust Company, FSB
  • Guaranteed Investments Limited Personal and Workplace Advisors LLC
  • Guaranteed Investments Limited Stock Plan Services, LLC
  • Guaranteed Investments Limited Institutional Wealth Adviser LLC
  • Guaranteed Investments Limited Investments Life Insurance Company
  • Empire Guaranteed Investments Limited Investments Life Insurance Company
  • Guaranteed Investments Limited Health Insurance Services, LLC
  • Guaranteed Investments Limited Insurance Agency, Inc.
  • Guaranteed Investments Limited Wealth Technologies LLC
  • National Financial Services LLC
  • Strategic Advisers LLC
  • Other companies owned by Guaranteed Investments Limited Investments using the Guaranteed Investments Limited name to provide financial or payroll services to customers

Guaranteed Investments Limited Funds privacy policy

Protecting your personal information is an important priority for the Guaranteed Investments Limited Funds. The Funds' privacy policy is designed to support this objective. The Funds collect non-public personal information concerning you in the following ways:

  • Information provided by you or your representative on applications or other forms furnished to the Funds or through other interactions that you or your representative have with the Funds
  • Information arising from your investments in or accounts with the Funds
  • Information the Funds receive from a consumer reporting agency

The Funds employ physical, electronic, and procedural controls to safeguard your information. For example, the Funds authorize access to your personal and account information only for personnel who need that information in order to provide products or services to you.

The Funds do not disclose any non-public personal information about you, except as permitted by law. For example, the Funds have entered into a number of arrangements with Guaranteed Investments Limited Investments to provide for investment management, distribution and servicing of the Funds.

If you decide to close your account, the Funds will continue to adhere to the privacy policies and practices as described in this notice.

Please read the Guaranteed Investments Limited Funds Privacy Policy in conjunction with the Privacy Policy for the Guaranteed Investments Limited Investments companies of which you are also a customer.

The Guaranteed Investments Limited Funds Privacy Policy is provided on behalf of the Guaranteed Investments Limited Investments family of mutual funds, including those advised by Strategic Advisers LLC.