These policies are effective as of [February 2016]. We reserve the right to make changes to these policies in the future.
What Information We Collect
This policy applies to information collected from the Athena website. Currently, we do not collect any personally identifiable information about visitors to our website, including any visitors’ names, addresses, phone numbers, social security numbers or email addresses. At times, visitors to our website may choose to email people at Athena using links available on our website; in such instances, a visitor’s email address may be collected as part of the process of sending the email to us in order to enable us to reply to those emails.
Our website uses “cookies” technology, through which small amounts of data are sent to your computer from our web server and stored on your computer’s hard drive. This data anonymously identifies you as a unique user when visiting our website, and helps us in the ongoing maintenance of our website. This technology does not provide us with any information about your name, address, phone number or email address, or any other personally identifiable information.
How We Use Information We May Collect
We do not share any information collected from our website with any parties outside of our company. Athena reserves the right to disclose any such information we do collect when required by a valid subpoena or court order, or as otherwise permitted or required by law. In the event that a visitor submits his or her email address or any other personally identifiable information to us through our website while requesting information or sending an email to someone at Athena, other than as described above, we do not use such information for any other purpose, and will not disclose such information to any outside party.
Other Third Party Websites
Athena is committed to safeguarding the confidential information provided to us by our current, prospective and former clients (collectively, “you”).
You provide us with nonpublic personal information about yourself and we collect nonpublic personal information about you from a variety of sources, including interviews and other conversations between you and our personnel, as well as other documents which you complete and submit to us.
We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law. Examples of disclosures that are permitted by law are disclosures to our accountants, auditors, and lawyers, disclosure to the regulators that examine our business, disclosure to investment funds and their respective managers if required in connection with an investment, disclosure to transfer agents, brokerage firms and the like, in connection with possible in-kind distributions to our clients, and disclosures that you specifically request. One type of disclosure that we may be required by law to provide to the federal government is information about your identity pursuant to the Patriot Act, including the International Money Laundering Abatement and Financial Anti-Terrorism Act.
We do not provide personal information about you to mailing list vendors or solicitors for any purpose. We restrict access to nonpublic information concerning each client to those employees who have a business reason to know that information. In addition, we maintain a secure office and computer environment to ensure that your information is not placed at unreasonable risk.