At Mount Lucas, your privacy is of the utmost concern. We have developed policies and procedures designed to safeguard your personal data. Our activities with regard to clients are governed by Regulation S-P, adopted by the SEC pursuant to the Gramm-Leach-Bliley Act of 1999, which is designed to maintain the privacy of non-public information about individuals. We also seek to comply with other regulations including the E.U. General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA).

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What information do we collect?

Mount Lucas gathers non-public personally identifying information: i) on applications and forms; and ii) about transactions involving Mount Lucas. 

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What information do we share?

We do not share any such information about current or former investors who are natural persons with any non-affiliated third parties except to the extent required or specifically permitted by law or reasonably necessary to prevent fraud, unauthorized transactions or liability. Furthermore, Mount Lucas does not share personally identifying information with all employees. We limit disclosures to those employees who have a legitimate business need for the information.

 

On occasion, laws and regulations may require disclosure of client information to government agencies and regulators. In addition, federal and state laws permit persons involved in litigation to obtain certain records. Mount Lucas shares only the information it is required or authorized to share. If a subpoena or other request compelling Mount Lucas to produce information is served on Mount Lucas, it should be brought to the attention of the Chief Compliance Officer.

 

How do we protect your data?

Mount Lucas has instituted physical, electronic and procedural safeguards which protect personally identifying information from disclosure and comply with federal and state standards.

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How do we keep clients up-to-date with our privacy policy?

This privacy notice shall be made available to individuals before we collect or process any data. The privacy policy shall be provided to individual investors when their accounts are opened and thereafter once in each calendar year.

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A note to California residents:

California law grants California residents certain rights, including: the right to opt out of the sale of their personal information, and the right to request a copy, deletion, and right to know regarding the use of their data. We do not sell personal information.

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How can you contact us?

For additional information, or to exercise any of your rights described above, you can contact us at 267-759-3500 or at clientservice@mtlucas.com.