Our Corporate Policy

During the course of our relationship, GATES Capital Corporation (hereafter “We” or “Us” or “Our”) collects and retains non-public information (“NPI”) about you (e.g. name, address, Social Security number, birth date, assets and income) from the following sources:

  • Investment applications, new account forms and other forms and agreements;
  • Transactions with us, our clearing firm, or other chosen investment sponsors; and/or
  • Other various materials utilized by your representative in order to put forth an appropriate recommendation or to fill a service request.

We may use this information in order to: develop, offer, and deliver products and services; process transactions in your account; respond to inquiries from you or your representative; or to fulfill legal and regulatory requirements.

We do not disclose/share any NPI of our customers or former customers to any unaffiliated third party unless:

  • It is necessary to fulfill a transaction or service request related to your account(s);
  • We are required to do so by a regulator, a court of competent jurisdiction or applicable law; or
  • It is by customer request.

As this is our practice, we are not required to have “Opt-out” provisions or methods per the exemptive relief provided under section 248.13 of the Gramm-Leach-Bliley Act.

We restrict access of NPI to required personnel in the provision of requested services and maintain physical, procedural and electronic safeguards that comply with federal standards.

If your account is closed, we many share your NPI with the new broker-dealer firm or custodian that you or your representative selects, in the process of transferring your account. If our representative servicing your account leaves us to join another broker-dealer firm, that representative is permitted to retain copies of your NPI, in order to assist in the transfer of your account and to continue to service you at the new broker-dealer firm. If you do not want us to share your NPI (other than as prescribed by law) with any unaffiliated third parties, including the registered representative servicing your account when he or she leaves us to join another broker-dealer firm, you should contact our Compliance Department by calling our toll-free number: 1-800-752-1018.