Arroyo Investment Group, LLC provides investment advisory services by means of its own internal operation. Arroyo Investment Group, LLC receives and maintains information about you that is related to and necessary for conducting investment advisory and consulting services for your account.
Where Do We Obtain The Information? The information that we have comes directly from you. This includes such information as your name (or trust name), address and social security number or tax identification number that you provided on applications, agreements or other forms. In addition, we may maintain records of each of your transactions and holdings processed with regards to your account.
To Whom Do We Disclose The Information? We provide information about current or former clients from the sources described above to parties outside of this firm only as described below:
To other companies as necessary to process your business. For example, we process your mutual fund and variable product transactions through product providers with whom we have dealer selling agreements. These parties must limit their use of the information to the purpose for which it was provided. In addition, client account records are reviewed by supervisory registered representatives of our affiliated broker dealer, Capital Research Brokerage Services, LLC that are also registered advisors of Arroyo Investment Group, LLC.
Where required by law or regulation. Examples include responses to a subpoena, court order or regulatory demand.
As authorized by you. You may direct us, for example, to send account statements or other account information to a third party.
As otherwise authorized or permitted by law. For example, the law permits us to respond to a request for information about you from a consumer-reporting agency.
Confidentiality and Security. We restrict access to information about you to those employees and authorized agents who need to know that information in order to provide products or services to you. We maintain administrative, physical, electronic and disposal safeguards to maintain the confidentiality of your information.
NONPUBLIC FINANCIAL INFORMATION POLICIES – REGULATION S-P
Policy to Safeguard Customer Records and Information
Our procedures are reasonably designed to:
(1) Insure the security and confidentiality of customer records and information;
(2) Protect against any anticipated threats or hazards to the security or integrity of customer records and information; and
(3) Protect against unauthorized access to or use of customer records or information that could result in substantial harm or inconvenience to any customer.
We restrict access to nonpublic personal information about customers to those employees who need to know that information to provide products or services to customers or as is otherwise permitted or required by law.
We electronically maintain and/or transmit to affiliated entities or service provider’s nonpublic personal information on or over what are represented to us as and what we believe to be secure protocols. Access to this information is restricted to individuals who need to know that information to provide products or services customers expect to receive from us or as is otherwise permitted or required by law.
We maintain both electronic storage media and physical documents containing customer nonpublic personal information by means which we believe are secure and private. We transmit such information to affiliated entities or service providers (a) electronically, by means which we believe are secure, and (b) physically, by the United States Postal Service or independent overnight courier.
We require that customer records and information be properly disposed of to protect against unauthorized access and use of consumer records and information.
WEBSITE VISITORS: HOW WE KEEP YOUR INFORMATION CONFIDENTIAL
No sharing or selling of email or phone numbers. Arroyo Investment Group LLC does not sell, rent, share, or otherwise give your personally identifiable information to third parties for marketing purposes.
Email policy. If you contact us, your email will be used to deliver emails requested and, also to send periodic follow up emails and marketing materials. You may opt out of these lists at any time by contacting us or unsubscribing.
ADV Part 2 Available upon request
If you have any questions on these policies, please contact us at Arroyo Investment Group, LLC, 15 South Raymond Avenue, Suite 200, Pasadena, California, 91105.