PRIVACY POLICY

Our Commitment to You
Ridgeway Lane, LLC (“Ridgeway Lane” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”).

This Policy is addressed to any current clients and/or prospective clients of Ridgeway Lane, LLC (“you” or “your”) whose public and non-public personal information Ridgeway Lane collects and controls to conduct its business, including on our website (“Site”).

Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Ridgeway Lane (also referred to as “we,” “our,” and “us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you.

Ridgeway Lane does not sell your personal information to anyone, nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below.

Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy.

Why You Need to Know

Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account(s). Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information through the sources identified below and on our Site. This Policy describes how we collect and use your personal information during and after your working relationship with us. This Privacy Policy describes the basis upon which and for what purposes we process your personal information, as well as your privacy rights under certain privacy laws, including where applicable, under US Privacy Laws and the General Data Protection Regulation (“GDPR”), and how we protect your personal information. To the extent GDPR applies, personal information and nonpublic information includes personal data, as defined under the GDPR.

To affirm our continued commitment to the proper use of client information and protecting your privacy, we have set forth the following privacy policies.

Changes to Our Policy

Our Policy may be periodically revised on this website, and the date of the most revised version is listed below. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing.

What Information Do We Collect From You?

When you establish a relationship with us, you are requested to furnish personal and financial information to assist in assessing your financial objectives and goals. The information you share with us is private and confidential, and we are committed to protecting your privacy. In addition to the information collected during the course of our relationship, we may also collect a variety of nonpublic and public personal information from other sources.

  • Social security or taxpayer identification number

  • Name, address, and phone number(s)

  • Income and expenses

  • E-mail address(es)

  • Account information (including other institutions)

  • Assets and liabilities

  • Investment activity

  • Investment experience and goals

The specific types of personal information we collect and share depend on the service you have with us. This information can include:

  • Personally identifying information such as name, telephone, address, date of birth, social security number, government identification, and marital status

  • Digital footprint data such as e-mail, login information, and IP addresses

  • Biographical data such as age and gender

  • Employment data such as salary information, job position, and tax information

  • Financial information such as bank information, salary information, credit card numbers, and pension

What Information Do We Collect From Other Sources?

  • Custody, brokerage, and advisory agreements

  • Account applications and forms

  • Other advisory agreements and legal documents

  • Investment questionnaires and suitability documents

  • Transactional information with us or others

  • Other information needed to service account(s)

How is Your Personal Information Used?

We will only use your personal information for the purpose of providing you with our investment services. In managing your investment, we will use your personal information to:

  • Monitor, audit, evaluate, and otherwise administer our services

  • Provide you with access to protected areas of our Site

  • Provide continuous service and conduct business processing functions, including by providing personal information to our related bodies corporate, contractors, service providers, or other third parties

  • Assist with the administrative, marketing, planning, product or service development, quality control, or research purposes of Ridgeway Lane and its contractors and service providers

  • Communicate with you and respond to your inquiries

  • Conduct investigations and comply with applicable legal requirements, relevant industry standards, contractual obligations, and our policies and terms

  • For other purposes required or authorized by law, including other purposes for which you have provided consent

  • Protect against, identify, and prevent fraud, copyright infringement, unauthorized use and distribution of protected content, and other unlawful activity, claims, and liabilities

  • Perform data analyses (such as market and customer research)

If we use personal information we collect for other purposes not identified above, where direct client consent is required under applicable rules, laws, and/or regulations, we will provide specific notice at the time we collect such personal information.

What Lawful Basis for Processing Do We Have to Process Your Personal Information?

Ridgeway Lane may have one or more of the following lawful bases to process your personal information:

  • Consent: Your freely given, informed, and voluntary consent to process your personal information in connection to our investment services.

  • Contract: Processing your personal information is necessary to fulfill a contract.

  • Legal Obligation: Processing is necessary to comply with applicable rules, laws, and regulations.

  • Legitimate Interests: Processing is necessary for the legitimate interests of our firm and/or a third party.

How Do We Share Your Information?

An RIA shares Client personal information to effectively implement its services. We may share your personal information for purposes including:

Servicing our Clients: We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, and other financial institutions) as necessary to provide agreed-upon services to you, consistent with applicable law, including but not limited to: processing transactions, general account maintenance, and responding to regulators or legal investigations.

Do We Share? Yes
Can You Limit? No

Marketing Purposes:
Ridgeway Lane does not disclose, and does not intend to disclose, personal information with non-affiliated third parties for marketing purposes.

Do We Share? No
Can You Limit? Not shared

Authorized Users:
Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent(s) or representative(s).

Do We Share? Yes
Can You Limit? Yes

Information About Former Clients

Ridgeway Lane does not disclose and does not intend to disclose non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients.

Do We Share? No
Can You Limit? Not shared

Contact Us

If you have any questions regarding this Privacy Policy or would like to exercise your rights, you may contact our office using the information below:

Ridgeway Lane, LLC
Ridgeway Lane LLC
42 Lorraine Road
Westwood, MA 02090
United States

E-mail: info@ridgewaylane.com
www.ridgewaylane.com