Privacy Policy

Pursuant to applicable federal and/or state privacy regulations ATCapital Management Corp. (referred to as “ATCM”) is a financial institution that has determined to keep confidential nonpublic personal information about each AT client.

Nonpublic personal information is defined to mean personally identifiable financial information that is provided by a consumer to a financial institution, results from any transaction with the consumer or any service performed for the consumer, or is otherwise obtained by the financial institution.

Personally identifiable financial information means any information:

  1.  A consumer provides to a financial institution to obtain a financial product or service;
  2. About a consumer resulting from any transaction involving a financial product or service between a financial institution and a consumer; or
  3. A financial institution otherwise obtains about a consumer in connection with providing a financial product or service to that consumer.

ATCM maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”). Through this policy and its underlying procedures, AT attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.

It is the policy of ATCM to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services to the client.

ATCM may disclose the client’s information if ATCM is:

  1. Previously authorized to disclose the information to individuals and/or entities not affiliated with ATCM, including, but not limited to the client’s other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, etc.);
  2. Required to do so by judicial or regulatory process; or
  3. Otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations.

The disclosure of information contained in any document completed by the client for processing and/or transmittal by ATCM in order to facilitate the commencement/continuation/termination of a business relationship between the client and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by the client for ATCM (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider.

ATCM permits only authorized employees and affiliates who, through signature, have agreed to the terms of ATCM’s Privacy Policy to have access to client information. Employees violating ATCM’s Privacy Policy will be subject to ATCM’s disciplinary process. Additionally, whenever ATCM hires other organizations to provide services to ATCM’s clients, ATCM will require them to sign confidentiality agreements and/or the Privacy Policy.

WEB SITE PRIVACY POLICY (the “Web Site”) will collect no personally identifiable information about visitors to the Web Site unless visitors choose to provide that information. This Privacy Policy does not describe information collection practices on other sites, including those linked to or from the Web Site.

The server on which the Web Site is located collects and saves only the default information customarily logged by web server software. Such information may include the date and time of visits, the originating IP address, and the pages and images requested.

Visitors to the Web Site agree to indemnify, defend, and hold harmless the Web Site and its members, managers, officers, employees, agents, and the assigns of same, from and against any and all loss, costs, expenses (including reasonable attorneys’ fees and expenses), claims, damages, and liabilities related to or associated with the use of the Web Site and any violation of this Privacy Policy.

This Privacy Policy constitutes a contract made under and shall be governed by and construed in accordance with the laws of the State of Iowa.

Questions or comments regarding the Web Site or this Privacy Policy should be sent by e-mail to or by U.S. mail to ATCapital Management 895 Main Street, Dubuque, IA 52004-0938