Agincourt Capital Management Privacy Policy
Effective date: December 3, 2025
Agincourt Capital Management, LLC (“Agincourt” or “the Firm”) is a Registered Investment Adviser dedicated to protecting the privacy and confidentiality of our clients’ personal information. This policy describes how we collect, use, disclose, and protect nonpublic personal information, consistent with applicable laws in the United States and other jurisdictions where we conduct business.
Information We Collect
We collect only the personal and financial information necessary to provide investment advisory services, administer client accounts, and comply with legal and regulatory requirements. This information may be obtained directly from clients or their authorized representatives, or through custodians and other service providers.
Examples include:
- Contact information (such as name, address, email, and phone number)
- Personal financial details
- Account numbers and tax identification numbers
- Other information required to fulfill our fiduciary and compliance obligations
We do not collect more information than is reasonably necessary for these purposes.
How We Use Information
We use personal information solely for purposes related to:
- Delivering investment advisory services
- Administering and maintaining client accounts
- Meeting legal, regulatory, and contractual obligations
We do not use client information for profiling, solicitation, or advertising purposes.
With respect to marketing materials, the Firm may reference institutional clients in client lists or representative client disclosures. Participation in such marketing is optional, and clients may opt out at any time. We do not include the names of personal or individual accounts in marketing materials.
Disclosure of Information
We do not sell or rent client information. We disclose personal data only as permitted by law and as necessary to provide our services and fulfill our fiduciary responsibilities. This may include:
- Service Providers and Custodians: We share information with custodians, consultants, brokers, and other third parties involved in account administration or transaction execution, typically at the direction of or on behalf of our clients.
- Affiliates: We may share information with our parent company Guardian Capital Group. Such sharing is limited to oversight, risk management, and compliance related purposes. Guardian Capital does not use this information for marketing, and access is restricted to those with a legitimate business need.
- Auditors and professional advisers: Independent consultants or auditors may review client information under confidentiality agreements.
- Regulators and government authorities: Federal and state regulators may review firm records as permitted by law. Certain laws (such as the US PATRIOT Act) may require us to provide specific information to government agencies.
- Brokerage Firms: Federal regulations permit us to share limited information with brokers to execute securities transactions on behalf of our clients.
We limit employee and agent access to personal information to those with a legitimate business or professional reason. All third parties with access are required to maintain the confidentiality of the client information.
Data Protection Rights
Individuals located in certain jurisdictions may have rights under applicable privacy laws, including the right to:
- Access personal information we maintain about them
- Request corrections or updates
- Request deletion of personal information, subject to legal and regulatory recordkeeping requirements
To submit a request, please contact our Compliance Officer at erika.banks@agincourtcapital.com. We will verify your identity and respond in accordance with applicable law. Some information may be retained as required under regulatory or contractual obligations.
Information Security
We maintain physical, electronic, and procedural safeguards designed to protect personal information from unauthorized access, alteration, or misuse. Sensitive data, including Social Security Numbers and bank account information, are stored and transmitted through secure systems.
Access to client information is limited to personnel with a legitimate business need, and all staff are expected to handle client information with discretion and professionalism. We periodically review our safeguards and reinforce sound practices to maintain the confidentiality and integrity of client data.
Incident Response and Breach Notification
Agincourt maintains a written incident-response program designed to detect, respond to, and recover from unauthorized access to client information. If a breach involving personal information occurs, we will notify affected individuals as soon as practicable, and no later than 30 days after determining that unauthorized access is reasonably likely to have occurred, unless delayed by law enforcement.
Service Provider Safeguards
We require all service providers with access to client information to maintain appropriate administrative, technical, and physical safeguards. We also oversee service providers, consistent with Regulation S-P, to ensure they maintain these protections.
Former Clients
We continue to protect the personal information of former clients in the same manner as current clients.