Glacier Investment Office, LLC (referred to as “Glacier”) maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”). Through this policy and its underlying procedures, Glacier 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 general policy of Glacier to restrict access to all 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 in furtherance of the client's engagement of Glacier. In that regard, Glacier may disclose the client’s information: (1) to individuals and/or entities not affiliated with Glacier, including, but not limited to the client’s other professional advisors and/or certain service providers that may be recommended or engaged by Glacier in furtherance of the client's engagement of Glacier (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, record keeper, proxy management service provider, etc.); (2) as required to do so by judicial or regulatory process; or (3) as otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations.

For the avoidance of doubt, non-affiliates with which Glacier may share information can include certain approved cloud-based data storage and management platforms and artificial intelligence tools and platforms for internal training, compliance monitoring, service delivery, and general administrative purposes. Information shared with these platforms can include, but is not limited to, screen or video recordings, documentation, or communications, as well as the information types described above. Glacier only permits the submission of confidential client information to such platforms and tools when Glacier reasonably believes that the subject platform or tool will provide at least the same degree of confidentiality and protection to client information that Glacier provides. Notwithstanding this, Glacier generally attempts to limit and, where applicable, redact sensitive client information that is submitted to these platforms and tools.

The disclosure of information contained in any document completed by the client for processing and/or transmittal by Glacier to facilitate the commencement/continuation/termination of a business relationship between the client and/or between Glacier and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, record keeper, insurance company, etc.), including, but not limited to, information contained in any document completed and/or executed by the client in furtherance of the client's engagement of Glacier (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.

Except as discussed above, Glacier permits only authorized employees and affiliates who have signed a copy of Glacier's Privacy Policy to have access to client information. Employees violating Glacier’s Privacy Policy will be subject to Glacier’s disciplinary process. Additionally, whenever Glacier hires other organizations to provide services to Glacier's clients, Glacier will require them to sign confidentiality agreements and/or the Privacy Policy.

Should you have any questions regarding the above, please contact us at hello@glacierhq.com.