Allos Investment Advisors, LLC (“Allos”), 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, Allos attempts to secure the confidentiality of customer records and information and protect against unanticipated threats or hazards to the security or integrity of customer records and information.
 
It is the policy of Allos 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 to the client. Allos may disclose the client’s information if Allos is: (1) previously authorized to disclose the information to individuals and/or entities not affiliated with Allos, including, but not limited to the client’s other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker- dealer, investment adviser, plan administrator, account custodian, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. The disclosure of information contained in any document completed by the client for processing and/or transmittal by Allos in order to facilitate the commencement/continuation/termination of a business relationship between the client and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by the client for Allos (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.
 
To ensure protection against identity theft Allos has implemented an Identity Theft Protection Program (ITPP) that controls reasonably foreseeable risks to our clients or to the safety and soundness of our firm from identity theft. We have developed our ITPP to adequately identify and detect potential red-flags to prevent and mitigate identity theft.
 
Under Regulation S-AM, a registered investment adviser is prohibited from using eligibility information that it receives from an affiliate to make a marketing solicitation unless: (1) the potential marketing use of that information has been clearly, conspicuously and concisely disclosed to the consumer; (2) the consumer has been provided a reasonable opportunity and a simple method to opt out of receiving the marketing solicitations; and (3) the consumer has not opted out.
 
Allos permits only authorized employees and affiliates who have signed a copy of Allos’ Privacy Policy to have access to client information. Employees violating Allos’ Privacy Policy will be subject to Allos’ disciplinary process. Additionally, whenever Allos hires other organizations to provide services to Allos’ clients, Allos will require them to sign confidentiality agreements and/or the Privacy Policy.
 
Any questions regarding Allos’ Privacy Policy should be directed to John Fales, Lead Advisor and Chief Compliance Officer of Allos at John@AllosAdvisors.com or (913) 948-7788.