PRIVACY POLICY

CEERA Investments, LLC (CEERA), as a Registered Investment Adviser, is covered under the definition of a “financial institution” under the Gramm-Leach-Bliley Act and the Securities and Exchange Commission’s (“SEC”) Privacy of Consumer Financial Information Rule (“Regulation S-P”).

The Firm realizes that providing personal information is an act of trust. The Firm values its clients’ trust and confidence. We will never sell or share the nonpublic personal information obtained from or in reference to clients. All information provided by clients to CEERA and its employees, and information and advice furnished to clients by us, shall be treated as confidential and shall not be disclosed to affiliated or unaffiliated third parties, except as permitted or directed by clients with written authorization, by application to facilitate the investment services offered by the firm via an unaffiliated financial services provider, or as required by any rule, regulation or law.

Commitment to Clients’ Private Information. CEERA is committed to safeguarding the confidential information of its clients. CEERA holds all personal information provided by clients in the strictest confidence and it is the objective of the firm to protect the privacy of all clients.  Except as permitted or required by law, CEERA does not share confidential information about clients with non-affiliated parties. It is our policy 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/non-affiliated entities who need to know that information in order to provide services in furtherance of the client’s engagement of CEERA. CEERA permits only authorized employees and affiliates (if applicable) who have acknowledged receipt and understanding of our Privacy Policy to have access to client information. Employees violating CEERA’s  Privacy Policy will be subject to our disciplinary process. If there are any changes to this policy, we will provide clients with written notice and clients will be provided an opportunity to direct CEERA as to whether such changes are permissible.

Why We Collect and How We Use Information. To conduct regular business, CEERA may collect personal client information (including client personal identification information) from sources such as:

–Information reported by the client orally or on applications or other forms the client provides to the firm (Such as investment advisory agreements, brokerage account applications, and other documents completed while opening and maintaining accounts with us.)
-Information about the client’s transactions implemented by the firm or others
-Information developed as part of financial plans, analyses, or investment advisory services
– Information we receive from third parties (Such as brokerage firms, outside managers and banks about transactions with us or with others)

To administer, manage, service, and provide related services for client accounts, it is necessary for CEERA to provide access to client information within the firm and to non-affiliated companies, with whom we have entered into agreements.

The disclosure of information contained in any document completed by the client for processing and/or transmittal by CEERA  to facilitate the commencement/ continuation/ termination of a business relationship between the client and/or between CEERA  and a non-affiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, record keeper, insurance company, etc.), including, but not limited to, information contained in any document completed and/or executed by the client in furtherance of the client’s engagement of CEERA  (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding non-affiliated third-party service provider.

Sharing of Information. Protecting privacy of former, existing and prospective clients.
No confidential information, including nonpublic personal information, whatever the source, regarding any client (as current, former, or prospective clients), may be disclosed except as follows:

• To other employees in connection with Ceera’s business.
• To an affiliate (if applicable), but the affiliate may disclose the information only to the same extent as Ceera is permitted to do so and no information may be disclosed if the client has directed that the information not be disclosed.
• To service and maintain customer accounts including effecting transactions in the accounts. This may include disclosing to individuals and/or entities not affiliated with CEERA, including, but not limited to the client’s other professional advisors and/or certain service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, record keeper, proxy management service provider, etc.) that may be recommended or engaged by CEERA in furtherance of the client’s engagement of CEERA
• When client may have specifically authorized and directed us to do so, and
• When required by law. Such as when our books and records are examined by federal or state regulators.

  Because CEERA shares nonpublic information solely to service client accounts, the firm does not disclose any nonpublic personal information about the firm’s customers or former customers to anyone, except as permitted by law. In the event that the firm has a change to its client privacy policy that would allow it to disclose non-public information not covered under applicable law, the firm will allow its clients the opportunity to opt out of such disclosure. Finally, CEERA strives to only recommend financial services providers that share its privacy policies; however, clients are encouraged to request each specific firm’s written policy for review.

Information Security and Safeguarding. CEERA maintains physical, electronic, and procedural safeguards to protect its clients’ nonpublic personal information. Through this policy and its underlying procedures, CEERA 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. CEERA maintains client records in a controlled environment and records are only available to authorized persons of the firm who have a need to access client information in order to deliver advisory services or respond to client requests.   CEERA’s policy to protect client information extends beyond the termination of the Investment Advisory Agreement.

Former Clients. Even if we cease to provide a client with services, our Privacy Policy will continue to apply to them, and we will continue to treat a former client’s nonpublic information with strict confidentiality per our privacy policies and procedures.

Changes to this Policy. CEERA will provide each client with initial notice of the firm’s current privacy policy when the client relationship is established. We will also provide each client with a new notice of the firm’s current privacy policy at least annually. If, at any time, CEERA adopts material changes to its privacy practices, the firm shall provide each client with a revised notice reflecting the new privacy practices.

Methods to Contact Us and Change Privacy Preferences: Clients are encouraged to discuss any questions regarding privacy policies and procedures directly with Rajesh Chelapurath, Chief Compliance Officer (CCO) of CEERA. Contact information:  rc@ceera.com or via 713-364-6770. Clients can also request changes to their privacy preferences, as applicable, by contacting our CCO.