​Privacy Notice

Chronos Capital Advisors LLC (“Chronos”) understands the importance our clients place on the privacy and security of their personal information. Chronos is committed to safeguarding the personal information that we obtain from our clients and maintaining the confidentiality, integrity and security of our clients’ personal information.  Chronos has prepared this policy statement to inform our clients of the type of personal data we obtain, the purposes for which we obtain this information, share or disclose our client’s personal data and safeguards in place to secure our client’s personal data.
This updated Privacy Policy (“policy”) includes details regarding how and why we collect, store, use and share your personally identifiable information (“PII”) and other personal data when you conduct business with us, use the website or by other means.  Please read this policy completely and carefully to understand what we do regarding your personal data.
Information We Collect from Our Clients
Chronos collects all personal information necessary for us to run our business, process client transactions, and service client accounts.  Personal information Chronos may collect, store, use and share includes information our clients provide us on new account applications or other account opening forms. We may also obtain information regarding our client’s credit history from custodians and other service providers, credit bureaus, consumer reporting agency, or other sources. Such as information obtained from and publicly available sources (internet, and/or free public sources available through public or private organizations).
PII is generally defined as information that may be able to identify you such as, but not limited to, your name, address, telephone number, email address, other contact information, social security or tax identification number, bank account number or code, photograph, age, or other types of information.
We may also collect personal information regarding your investment objectives,  investment experience, employment history, account balances, transaction history, payment history account experience, socio-demographic information, technical information, behavioral information (i.e. use of products and services), communication information (e.g. records of phone calls, emails and instant messages), publicly available data (i.e. information in public records or other publicly accessible information), sensitive data (e.g. criminal records, to the extent the law permits us to collect such information)
Even if you are no longer a client of Chronos, we may continue to store and share your information as described herein.
Collection and Use of Personal Data
Chronos may collect PII and other personal data through our website or other means when you: enter into an advisory agreement, enter data such as your name, address, email, and phone number to register with us for use of our website, sign up to receive any communications from us by email, represent one of our institutional customers, Work with Chronos as a service provider and/or Visit our offices or register to attend a Firm sponsored event
Chronos collects, stores, uses and shares your data for its everyday business purposes such as: Maintaining your account, Processing your transactions, Managing our relationship with our clients and keeping clients informed of products and services and important or relevant changes in policies such as this Updating our records, Delivering or administering our products and services, Seeking your consent to contact you as needed or required by law
Responding to court orders or other legal or law enforcement inquiries or investigations for crime prevention and detection objectives, Marketing and offering our products and services, Sharing information about your transactions with our service providers for business purposes
Chronos will only collect, use and share your personal data where we have reasonably determined that we have the proper legal basis for doing so.  For example, we will use your personal information where it is necessary to:
Fulfill a contract we have with you or to enter into a contract with you; Comply with  our legal obligations, such as reporting to regulatory authorities; or, Comply with regulatory reasons in the public interest and prevent and detect financial crimes.
We may also use your information where you have provided your consent to use such information for purposes such as receiving marketing communications, or we have another legitimate interest in providing services to you as a client.
Maintaining Accurate Information
It is very important for Chronos to maintain accurate and updated client information.  It is the client’s responsibility to promptly notify Chronos of any changes to their account information or personal circumstances.  Clients are requested to promptly inform Chronos of any changes and update or correct any inaccurate or incomplete information. Some or part of your personal  information may be updated from time to time after its initial collection. Inaccurate information may be rectified, and/or disregarded and or/ deleted and clients and contacts may request to do so and in accordance and under the applicable terms and conditions, if any, of the relationship with Chronos.
Access to and Review of Personal Data
In accordance with applicable laws or regulations, you may confirm whether we maintain any of your personal data, request a copy of such data, or request that we correct any personal data Chronos possesses that may be inaccurate or incorrect.
Other Legal Rights to Manage Your Data
In addition to requesting access to and correcting your personal information you also may have rights to take certain actions such as erasing or restricting the transfer and processing of your personal information.  You may also have the rights to file a complaint with your local supervisory authority. In this regard, you may also contact us directly to address your concerns or requests.  Depending on the nature of the request, Chronos may take whatever action is appropriate or required by law.
You can request that we erase personal information in limited circumstances where: It is no longer needed for the purpose for which it was collected; You have withdrawn your consent for us to use your information; Where you have successfully objected to our right to use your information for a certain purpose; Your information was processed unlawfully; or To comply with a legal obligation to which Chronos is subject.
Protecting Client’s Personal Information
To protect our client’s personal information from unauthorized access and use, we maintain commercially reasonable physical, electronic and procedural safeguards to protect our client’s personal information. These security measures include computer safeguards and secured files and buildings. Our technology vendors provide security and access control over personal information and have policies over the transmission of data.  We require third parties service providers to protect our client’s personal information
Chronos’s employees are subject to a Code of Ethics and strict policies requiring confidential treatment of customer information. Employees are required to access client information only for legitimate business purposes.  Employees are trained on the proper safeguarding of customer information and are subject to disciplinary action for failing to follow our policy.
Use and Disclosure of Client’s Personal Information
Chronos does not sell, share or disclose, nor intend to sell share or disclose our client’s personal information to marketers. As permitted by law, we may share our client’s personal information with agents or third party providers inside or outside the client’s country of residence, for the purpose of servicing the client’s account. Our agents and third party service providers who have access to our client’s personal data are required to maintain policies to safeguard their data. Chronos may also disclose or report personal information to custodian(s), securities broker-dealers, investment advisors, or other financial institutions subject to the same type of restrictions as we are on disclosing personal information.
Chronos may disclose or report personal information to nonaffiliated third parties as permitted by law, or to perform necessary services. Nonaffiliated third party service providers include: attorneys, accountants, consultants, data processing companies, record storage companies, courier and mailing services. These service providers assist Chronos in fulfilling legal obligations, processing transactions and service requests.  Service providers acting on Chronos’s behalf are contractually obligated to safeguard our client’s personal data, treat information provided by Chronos strictly confidential, and use the information solely in connection with providing services requested by Chronos.
 Limits on Sharing Information
You may limit certain uses of your personal data such as: Sharing information about your creditworthiness for an affiliates’ everyday business purposes, Affiliates’ use of your information to market services and products to you
Sharing for non-affiliates to market to you
Information Transmitted Over the Internet
While Chronos uses commercially reasonable technical and organizational methods to protect electronic communications to and from Chronos, we do not accept responsibility or liability for the security of information transmitted over the Internet and encourage our clients to use other means of communication to transmit sensitive personal information to us.
The Internet is not deemed to be a secure environment. Information transmitted through the Internet may be intercepted by unauthorized third parties.  This may result in among other things: unauthorized disclosure of client’s personal information changes to the content of the communication, or transmission failures.  Additionally, even when both the sender or receiver are located in the same country, information transmitted via the Internet may travel across international borders to a country with lower data protection levels or standards. Chronos is not responsible for the security of your personal data while it is being sent to the Firm over the Internet.  Accordingly, you may choose not to transmit personal data through such means and elect another method of communication with Chronos.
Global Transfer of Personal Information
When using our website, we may collect, store, use and disclose your personal data which you have entered for any of the purposes stated above that you have agreed to receive, in accordance with this policy.  If you are a resident of the European Union, (“EU”) you acknowledge that Chronos may transfer and store your personal data in countries outside the EU, including the US and other countries which may have different standards of data protection. Chronos will take the appropriate measures to ensure that any such transfers are in accordance with applicable laws and that your personal data will be adequately protected.
Review, Disclosure and Storage of Electronic Communications
Electronic communications to and from Chronos are subject to review by appropriate supervisory personnel in our legal, compliance, audit or risk departments, our outside auditors or consultants and appropriate regulatory authorities, or governmental agencies, to ensure compliance with applicable regulatory obligations. 
As stated above, Chronos  may disclose your personal information to its agents and third-party providers (both inside and outside your country of residence) to perform services for Chronos and for the purposes set forth above. Our agents and third-party providers who have access to personal data obtained from our website also must comply with privacy requirements. Where we transfer your personal data internationally we make sure we comply with applicable laws and regulations by entering into agreements to ensure that the recipients of the personal data also maintain adequate protection for such data.
Chronos may also disclose personal data to others within the Firm, governmental agencies, regulatory authorities, or other persons in accordance with applicable law, regulations, court order or other official request for such information, or under any or for the purposes of any regulatory guidance, or any other process required or permitted by applicable law.  Within Chronos such disclosure will be as necessary to provide you with our services or manage our business.  With third parties, we will share your information as needed to help manage our business and deliver our services.
Data Storage
Chronos will store your data for as long as is reasonably necessary for the purposes for which it was originally collected. In addition, there may be circumstances for which we may store your data for longer periods of time as necessary in accordance with legal, regulatory, tax, accounting or technical requirements.
Questions about Our Policy
We may update this policy notice from time to time.  If any changes to our policy affect how we treat or handle PII already provided to us by you, we will use commercially reasonable efforts to notify you by email (if we have a valid email address to use) and provide you thirty (30) days to opt out of the changes as they pertain to such PII. Our clients may review Chronos’s current privacy policy by contacting us to obtain a copy. Please contact us with any questions about our policy.