In providing investment advisory services, Stairway Partners must collect certain nonpublic personal information about our clients. Stairway is committed to protecting the privacy of both our current and former clients. Our policy is to keep our clients’ personal information confidential. We take steps to safeguard this data from anyone who should not have access to it and only use or disclose information as necessary to provide advisory services to our clients.
Information We Collect
The nonpublic personal information we have about our clients includes what they provide to us when opening an account or communicating with us. This may include:
• Name and address
• Social Security Number
• Investment objectives
• Employment
• Asset values and account transactions
Information We Disclose and How it is Used
Stairway uses nonpublic personal client information as part of its everyday business activities in order to provide investment advisory services. As permitted by law, we may disclose this information to unaffiliated third parties, such as executing brokers and custodians that we use as part of providing advisory services to clients. From time to time Stairway must also give information about its business to regulatory authorities. This may include nonpublic personal information about clients. Stairway does not sell nonpublic client information to anyone.
How Information is Safeguarded
Stairway has procedures in place that are designed to protect the privacy of our clients’ nonpublic personal information. We internally safeguard this information by restricting access to only those employees who provide services, or need access to personal client information to service an account. Stairway maintains physical, electronic and procedural safeguards to protect nonpublic personal client information.
