Privacy Policy

VOLUMETRIC ADVISERS INC.
Privacy Policy


 In the course of its relationship with clients, Volumetric Advisers Inc. (the “Adviser”) will gather and maintain personal, nonpublic information regarding its clients. The Adviser is committed to maintaining the privacy and confidentiality of this client information. Accordingly, the Adviser has adopted this privacy policy regarding disclosure of non-public personal information that clients provide to the Adviser or that the Adviser collects from other sources. If working with a broker-dealer or other financial intermediary, the privacy policy of the financial intermediary would govern how client’s nonpublic personal information would be shared with nonaffiliated third parties. This policy is designed to be in accordance with SEC privacy regulations, which require investment companies to determine and disclose how they treat nonpublic information about their clients and potential clients. 
         
  
Categories of Information the Adviser May Collect
The Adviser may collect the following nonpublic personal information about its clients and potential clients from the following sources:

• Information received from a client on applications or other forms, correspondence, or conversations (such as the client’s name, address, phone number, social security number, and date of birth); and

• Information about the client’s transactions with the Adviser, its affiliates, or others (such as the client’s account number and balance, payment history, cost basis information, and other financial information).

• Information received from third parties (such as brokers, financial planners or other intermediaries hired by the client).

• Cookies.  Our website does not use cookies or similar tracking technologies. We do not collect personal data through cookies for analytics, advertising, or other purposes. Our third-party email service provider may use web beacons and cookies for the strict purpose to determine if and when you received, opened, or clicked any links in the email blast. This information is not used for other purposes.

 
Categories of Information the Adviser May Disclose
The Adviser may not disclose any nonpublic personal information about its current, former or potential clients to unaffiliated third parties, except (i) as necessary to service client accounts including, without limitation, the settlement, billing, processing, clearing, or transferring of client transactions; (ii) as otherwise directed by a client; or (iii) as required or permitted by law. The Adviser is permitted by law to disclose all of the information it collects, as described above, to its service providers (such as the Adviser’s custodian, administrator, transfer agent, accountant, distributor, and legal counsel) to process client transactions and otherwise provide services to the client.
 
 
Confidentiality and Security
All client information is to be maintained in the Adviser’s client files and/or stored on appropriate electronic media. The custodian may maintain certain client files on the Adviser’s behalf. Information from potential clients may be filed in temporary files, but shall be subject to the same restrictions and limitations as other client files outlined below.
The Adviser shall restrict access to client nonpublic personal information to those persons who require such information to provide products or services to the client. The Adviser shall maintain physical, electronic, and procedural safeguards that comply with federal standards to guard client nonpublic personal information. Access to client files and information, whether in paper or electronic format, is limited to personnel of the Adviser and its service providers (e.g., custodian) for the purposes of servicing client accounts. 
 
Disposal of Information
The Adviser, through its custodian, have taken steps to reasonably ensure that the privacy of a client’s nonpublic personal information is maintained at all times, including in connection with the disposal of information that is no longer required to be maintained by the Advisers. Such steps shall include, whenever possible, shredding paper documents and records prior to disposal, and erasing and/or obliterating any data contained on electronic media in such a manner that the information can no longer be read or reconstructed.
 
Privacy Notice
The Adviser will provide clients with a privacy notice (the “Privacy Notice”) before or at the time the client invests with the Adviser.  The Privacy Notice shall detail the types of nonpublic client information collected, any information shared with third parties or with affiliates, the policies and practices the Adviser has in place to protect the confidentiality and security of nonpublic client information; and the procedures to permit clients or potential clients to opt out of information sharing arrangements with third parties (inapplicable to the Adviser and its service providers so long as sharing information is for the purpose of servicing client accounts).
The Adviser shall distribute its updated Privacy Notice to its clients on an annual basis, or as frequently as required by applicable regulations. The Adviser will direct each of its service providers to adhere to this Privacy Policy with respect to all consumer, customer and former customer information of the Adviser and to take all actions reasonably necessary so that the Adviser is in compliance with this Privacy Policy. 

A copy of the Privacy Notice for the Adviser is below as Appendix 1.