Privacy Policy

White Brook Capital LLC (“White Brook”) is a Registered Investment Advisor. White Brook may only transact business in those states in which it is registered or qualifies for an exemption or exclusion from registration requirements.  

 

White Brook’s website is limited to the dissemination of general information pertaining to its advisory services, together with access to additional investment-related information, publications, and links. Accordingly, the publication of White Brook’s website on the internet should not be construed by any consumer and/or prospective client as White Brook’s solicitation to effect, or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, over the internet. Any subsequent, direct communication by White Brook with a prospective client shall be conducted by a representative that is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides. 

 

For information pertaining to the registration status of White Brook, please contact the SEC or the state securities regulators for those states in which White Brook maintains a notice filing.  

 

A copy of White Brook’s current written disclosure statement discussing White Brook’s business operations, services, and fees is available from White Brook upon written request.  

White Brook does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to White Brook's website or incorporated herein, and takes no responsibility therefor. All such information is provided solely for informational purposes only and all users thereof should be guided accordingly. 

 

Please remember that different types of investments involve varying degrees of risk, and there can be no assurance that the future performance of any specific investment or investment strategy (including those undertaken or recommended by White Brook), will be profitable or equal any historical performance level(s). 

 

Certain portions of White Brook’s website (i.e. newsletters, articles, commentaries, etc.) may contain a discussion of, and/or provide access to, White Brook (and those of other investment and non-investment professionals) positions and/or recommendations as of a specific prior date. Due to various factors, including changing market conditions, such discussion may no longer be reflective of current position(s) and/or recommendation(s). Moreover, no client or prospective client should assume that any such discussion serves as the receipt of, or a substitute for, personalized advice from White Brook, or from any other investment professional. White Brook is neither an attorney nor an accountant, and no portion of the website content should be interpreted as legal, accounting or tax advice. 

 

To the extent that any client or prospective client utilizes any economic calculator or similar interactive device contained within or linked to White Brook’s website, the client and/or prospective client acknowledges and understands that the information resulting from the use of any such calculator/device, is not, and should not be construed, in any manner whatsoever, as the receipt of, or a substitute for, personalized individual advice from White Brook, or from any other investment professional. 

Each client and prospective client agrees, as a condition precedent to his/her/its access to White Brook’s website, to release and hold harmless White Brook, its officers, directors, owners, employees and agents from any and all adverse consequences resulting from any of his/her/its actions and/or omissions which are independent of his/her/its receipt of personalized individual advice from White Brook. 

 

​1. WEBSITE ACCESS ACKNOWLEDGMENT 

 

As a client of White Brook Capital LLC (“White Brook”), by selecting the “login” button, I elect to participate in the password-protected access portion of White Brook's internet website. I understand that my participation will allow me to review certain investment-related information published by White Brook and unaffiliated third parties. This password-protected access is made available to clients of White Brook free of charge. This authorization shall continue until canceled in writing. 

Further, by selecting the “login” button, I understand that the password-protected section is a secure website intended only to allow a client access to information relative to their specific account. I also understand that I will be assigned an individual password. I agree not to share my password with any other person. I hereby release and hold White Brook harmless from any adverse consequences relative to any failure by me to keep the identity of my password secure. 

2. PRIVACY STATEMENT 

 

White Brook Capital LLC (referred to as “White Brook”) maintains physical, electronic, and procedural safeguards to protect its clients’ nonpublic personal information (“information”). Through this policy and its underlying procedures, White Brook attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information. 

 

It is the policy of White Brook to restrict access to current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services to the client. White Brook may disclose the client’s information if White Brook is: (1) previously authorized to disclose the information to individuals and/or entities not affiliated with White Brook, including, but not limited to the client’s other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. The disclosure of information contained in any document completed by the client for processing and/or transmittal by White Brook in order to facilitate the commencement/continuation/termination of a business relationship between the client and a nonaffiliated third party service provider (i.e., broker dealer, investment adviser, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by the client for White Brook (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider. 

 

White Brook permits only authorized employees and affiliates who have signed a copy of White Brook’s Code of Ethics to have access to client information. Employees violating White Brook’s  Code of Ethics will be subject to White Brook’s disciplinary process. Additionally, whenever White Brook hires other organizations to provide services to White Brook’s clients, White Brook may require them to sign confidentiality agreements. 

 

Should you have any questions regarding the above, please contact White Brook Capital.