Privacy Policy

We may collect personal information that you voluntarily provide to us, including:

• your name;
• email address;
• telephone number;
• company or organization;
• job title or professional affiliation;
• investor type;
• information regarding the nature of your inquiry or request; and
• other information you choose to provide to us.

We may also automatically collect limited technical information when you use our website, such as your Internet Protocol address, browser and device information, pages visited, referring website, and information regarding your interaction with our website.

In connection with an actual or prospective advisory relationship, we may collect additional information as reasonably necessary to provide investment advisory services, satisfy regulatory requirements, conduct due diligence, or otherwise administer the relationship. Such information may constitute nonpublic personal information subject to applicable financial privacy laws.

We may use personal information to:

• respond to inquiries and requests;
• provide information regarding NOW Asset Management and its investment strategies or services;
• communicate with existing and prospective clients and investors;
• evaluate or establish prospective business relationships;
• administer client and investor relationships;
• operate, maintain, secure, and improve our website and information systems;
• maintain appropriate business and regulatory records;
• prevent fraud, unauthorized access, or other misuse; and
• comply with applicable legal, regulatory, and compliance obligations.

We do not use personal information for purposes materially different from those described above without an appropriate basis for doing so.

We may disclose personal information to service providers that perform services on our behalf or support our business operations, including providers of information technology, cybersecurity, cloud computing, website hosting, communications, professional services, administration, and other business infrastructure.

Where service providers have access to customer information, NOW Asset Management maintains policies designed to require appropriate safeguards for that information. The Firm’s information-security program also provides for oversight of service providers with access to customer information.

We may also disclose information:

• when required by applicable law, regulation, legal process, or governmental or regulatory authority;
• to protect the rights, property, security, or interests of NOW Asset Management, our clients, or others;
• in connection with a corporate transaction or reorganization; or
• with your authorization or at your direction.

NOW Asset Management does not sell personal information.

NOW Asset Management maintains administrative, technical, and physical safeguards designed to protect customer information and other confidential information against unauthorized access, use, disclosure, alteration, or destruction.

These safeguards include controls governing access to customer information and measures designed to protect information in storage and transmission.

No system of electronic transmission or storage can be guaranteed to be completely secure, however, and we cannot guarantee the absolute security of information transmitted through or stored in connection with our website or systems.

We retain personal information for as long as reasonably necessary for the purposes for which it was collected, including to satisfy legal, regulatory, compliance, accounting, recordkeeping, and legitimate business requirements.

NOW Asset Management maintains procedures governing the retention and secure disposal of customer information.

Our website may use cookies or similar technologies that are necessary for website functionality, security, performance, or analytics.

You may be able to control cookies through your browser settings. Disabling certain cookies may affect the operation or functionality of the website.

Most web browsers and some mobile operating systems include a Do Not Track (“DNT”) feature or setting you can activate to signal your preference not to have data about your online browsing activities monitored and collected. Because no uniform technology standard for recognizing and implementing DNT signals has been finalized, our website does not currently respond to DNT signals. If a standard for online tracking is adopted that we must follow in the future, we will describe that practice in a revised version of this Privacy Policy.

Third-party service providers, such as analytics providers, may collect information about your online activities over time and across different websites when you use our website.

Depending on your jurisdiction and applicable law, you may have certain rights with respect to your personal information, which may include rights to request access, correction, deletion, restriction, or other treatment of your personal information.

To make a privacy-related request, please contact us using the information below. We will consider and respond to requests in accordance with applicable law.

Certain information may be exempt from such requests or may need to be retained to satisfy legal, regulatory, contractual, or recordkeeping requirements.

As a registered investment adviser, NOW Asset Management is subject to privacy and information-security requirements applicable to financial institutions, including Regulation S-P under the federal securities laws.

Where applicable, clients and other natural persons with whom NOW Asset Management establishes a customer relationship may receive additional privacy notices concerning the collection, use, and disclosure of nonpublic personal information. Those notices supplement this website Privacy Policy and govern to the extent required by applicable law.

This website is intended for adults and is not directed to children. We do not knowingly collect personal information from children through the website.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other circumstances. The date shown at the top of this page indicates when the policy was most recently updated.

If you have questions about this Privacy Policy or wish to make a privacy-related request, please contact:

Email: info@nowassetmanagement.com