The information contained in this document is for background purposes only, does not purport to be full or complete, does not constitute investment advice and may not be relied on. In particular, strategies have been and will continue to be adjusted, modified, developed, added and/or removed, and there can be no assurance that the Fund will in the future exhibit the same target risk allocations or other characteristics noted herein. On the contrary, these characteristics will change in the future, perhaps materially. No prospective investor should invest based on the information contained herein.


Privacy Policy

Harmony Capital Advisors LLC ("Harmony Capital" or the “Company”) has adopted this privacy policy with recognition that protecting the privacy and security of the personal information we obtain about our customers is an important responsibility. We also know that you expect us to service you in an accurate and efficient manner. To do so, we must collect and maintain certain personal information about you. This privacy policy notice informs you on what information we collect and how we use and safeguard that information.

Information We Collect

We may collect certain non-public personal information about you ("Customer Information"). The essential purpose for collecting Customer Information is to allow us to provide advisory services to you. Customer Information we collect may include:

  • Information that you provide on applications or other forms. This Customer Information may include personal and household information such as income, investment objectives, financial goals, statements of account, and other records concerning your financial condition and assets, together with information concerning employee benefits and retirement plan interests, wills, trusts, mortgages and tax returns.
  • Identifying information such as your name, age, address, social security number, etc.
  • Information about your transactions with us, or others (e.g., broker-dealers, clearing firms, or other chosen investment sponsors and service providers).
  • Information we receive from consumer reporting agencies (e.g., credit bureaus), as well as other various materials we may use to provide an appropriate recommendation to you and services.

If you decide to become an inactive customer, we will adhere to our privacy policies, which may be amended from time to time.

Information We Disclose to Affiliates and Unaffiliated Third Parties

Harmony Capital has business relationships with our affiliates and with non-affiliated third parties (such as attorneys, auditors, accountants, brokers, custodians, investment advisers and other consultants), who, in the ordinary course of providing their services, may require access to your Customer Information. Harmony Capitals’s engagement with un-affiliated third-party service providers may be necessary for the Company to provide investment advisory services to you. In addition, the Company selects and retains service providers that it believes are capable of maintaining appropriate safeguards for Customer Information, and the Company will require written agreements from its service providers to maintain such safeguards.

We do not disclose Customer Information we collect about you except (i) to furtherance of our business relationship and only to those persons necessary to effect the transactions and provide the authorized services; (ii) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, consultants, etc.); and (iii) to our attorneys, accountants, and auditors.  

Harmony Capital may disclose information to non-affiliated third parties as required or allowed by law. For example, this may include disclosures in connection with a subpoena or similar legal process, a fraud investigation or a regulatory audit or examination.

We do not sell any Customer Information to any third party.

Opt-In Rights

Harmony Capital follows an “opt-in” provision as required by law.

Harmony Capital will not share non-public personal information with non-affiliated third parties unless a customer opted in of certain sharing through a signed statement in which you will make an affirmative declaration of permission to disclose such information.

There is no opt-in requirement for any disclosure of Customer Information to service providers or joint marketers, but Harmony Capital must disclose the nature of any information to be shared with a service provider or joint marketer and must enter into contractual arrangements to require the third party to maintain confidentiality of the information.

The opt-in requirement also does not apply to disclosure of confidential information in the following circumstances:

  • For resolving consumer or customer disputes or inquiries;
  • To persons holding a legal or beneficial interest relating to the consumer or customer;
  • To persons acting in a fiduciary or representative capacity on behalf of a consumer or customer;
  • To provide information to agencies assessing the Company's compliance with industry standards, and to the Company's attorneys, accountants, and auditors;
  • In connection with a proposed or an actual sale or merger of the Company;
  • To respond to a regulator’s examination of the Company; or
  • To comply with a civil, criminal, or regulatory investigation by federal, state, or local authorities.

Security of Your Information

Harmony Capital maintains physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your Customer Information. Computer security measures have been instituted where applicable including passwords, backups, and encryption. All employees are informed and instructed on various security measures including the non-discussion and/or sharing of Customer Information and restrict access to only those employees who need to know that information to service your account.

Harmony Capital uses various methods to store and archive client files and other information. In addition to electronic and personnel measures, the company has implemented reasonable physical security measures at our home office location to prevent unauthorized access to our facilities and all remote locations, where applicable.

Changes to Our Privacy Policy

In the event there were to be a material change to our privacy policy regarding how we use your Customer Information, we will provide written notice to you. Where applicable, you would be given an opportunity to limit or opt-out of such disclosure arrangements.

Supplemental Notice For California Residents

This NOTICE FOR CALIFORNIA RESIDENTS applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”).  

We collect and use personal information as described in this Privacy Notice. If a consumer wishes to have their personal information deleted, Harmony Capital will delete your personal information unless it is necessary for us to retain the personal information in compliance with applicable federal or state laws. All requests under the CCPA must be sent to Robin Wehbé telephonically by calling (603)-812-7357.

The consumer has the right to request a report concerning their personal information that contains the information specified in 1798.110 (a) of the CCPA: (1) the categories of personal information we have collected about you, (2) the categories of sources from which the personal information is collected, (3) the business or commercial purpose for collecting the personal information, (4) the categories of third parties with which we share the personal information, and (5) the specific pieces of personal information we have collected about you. As per your rights upon a request, Harmony Capital discloses to you that we do not sell your personal information and the categories of your personal information that we have disclosed is for a business purpose.

Harmony Capital does not discriminate against you for exercising any of your individual rights, such as by denying you products or services, charging you different prices or rates, or providing a different level or quality of products and services.


If you have questions about this privacy notice or about the privacy of your Customer Information, call our main number (603)-812-7357.