Effective Date: July 1, 2025
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At Keychain Asset Management (the “Firm”), we understand the paramount importance of protecting your privacy and the confidentiality of your personal and financial information. As an Oregon-registered investment adviser, we are committed to maintaining the highest standards of integrity and trust in all our relationships. This Privacy Policy outlines how we collect, use, share, and protect your non-public personal information.
This policy applies to individuals who obtain financial products or services from us for personal, family, or household purposes.
I. Information We Collect
We collect non-public personal information about you from the following sources:
- Information You Provide to Us: This includes information we receive from you on applications, forms, agreements, and other documents, whether written or electronic. Examples include your name, address, social security number, date of birth, financial circumstances, investment objectives, risk tolerance, and information about your digital asset holdings and activities.
- Information About Your Transactions: This includes information about your transactions with us, our affiliates, or others. Examples include your account balances, transaction history, investment activity, and payment information.
- Information from Third Parties: This may include information from custodians (e.g., Charles Schwab & Co., Inc., BitGo, Inc.), broker-dealers, digital asset exchanges, consumer reporting agencies, or other service providers, as necessary to provide our services or to comply with legal obligations.
II. How We Use Your Information
We use your non-public personal information to:
- Provide you with investment advisory services, including financial planning, wealth management, and digital asset portfolio management.
- Process your transactions and manage your accounts.
- Communicate with you about your accounts, services, and other relevant information.
- Comply with legal and regulatory requirements, including anti-money laundering (AML) laws, Know Your Customer (KYC) regulations, and reporting obligations.
- Personalize and improve our services to better meet your needs.
- Perform internal business operations, such as auditing, data analysis, and research.
III. Information We Share
Keychain Asset Management does not sell or rent your non-public personal information to anyone.
We may share your non-public personal information with the following types of non-affiliated third parties, but only as necessary to provide our services, operate our business, or as required by law:
- Service Providers: We may share information with non-affiliated companies that perform services on our behalf, such as custodians, broker-dealers, portfolio management software providers (e.g., Altruist), financial planning software providers (e.g., RightCapital), technology support providers, and compliance consultants. These service providers are contractually obligated to keep your information confidential and to use it only for the purposes for which we disclose it to them.
- Legal and Regulatory Authorities: We may disclose your information to government agencies, regulatory bodies (e.g., SEC, Oregon Division of Financial Regulation), or law enforcement officials when required or permitted by law, such as in response to a subpoena, court order, or regulatory inquiry, or to protect our rights or property.
- Other Permitted Disclosures: We may also disclose your information with your express consent or as otherwise permitted or required by applicable law.
IV. How We Protect Your Information
We are committed to protecting the security and confidentiality of your non-public personal information. We maintain physical, electronic, and procedural safeguards designed to:
- Protect against unauthorized access to or use of your information.
*Ensure the security and integrity of our systems and data. - Restrict access to your non-public personal information to only those employees, contractors, and service providers who need to know that information to provide services to you.
- Train our personnel on the importance of confidentiality and privacy.
Our cybersecurity and data privacy policies include measures such as:
- Secure storage of electronic and physical client records.
- Robust access controls and authentication procedures.
- Use of firewalls, antivirus software, and encryption technologies.
- Regular security updates and vulnerability assessments.
- Data backup and recovery procedures.
- An incident response plan to address potential data breaches.
V. Accuracy of Your Information
We strive to maintain accurate and up-to-date client information. We encourage you to review any statements or reports we provide and to notify us promptly of any changes to your personal information (e.g., address, phone number, email).
VI. Opt-Out Rights
Because we do not share your non-public personal information with non-affiliated third parties for their marketing purposes, there is no opt-out right for such sharing.
If we were to engage in future sharing of your information with non-affiliated third parties for purposes other than those necessary to provide our services or as required by law, we would provide you with a clear and conspicuous notice and the opportunity to opt-out of such sharing, as required by law.
VII. Changes To Our Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make material changes, we will provide you with a revised Privacy Policy notice and/or post the updated policy on our website. We encourage you to review this policy periodically.
VIII. Contact Information
If you have any questions or concerns about our Privacy Policy or the handling of your non-public personal information, please do not hesitate to contact us:
Keychain Asset Management
914 6th St Oregon City, OR 97045
Phone: 503-893-8385
Email: compliance@keychainassets.com