Varsity Capital Management, LLC, an investment advisory firm, is committed to safeguarding the confidential information of its clients. We do collect nonpublic personal information in order to open and administer your accounts with us and to provide you with accurate and pertinent advice. We hold all nonpublic personalinformation you provide to us in the strictest confidence. If we were to change our firm policy, we would be prohibited under the law from doing so without advising you first.
You may direct us not to make disclosures (other than disclosures required by law) regarding nonpublic personal information to nonaffiliated third parties. If you wish to opt out of disclosures to non‐affiliated third parties please contact us at (214) 843‐8977.
Varsity Capital Management, LLC, collects personal information about you from the following sources:
o Applications or other forms.
o Discussions with nonaffiliated third parties.
o Information about your transactions with others or us.
o Tax Returns.
o Estate Planning Documents.
Varsity Capital Management, LLC, uses your personal information in the following manner:
• We do not sell your personal information to anyone.
• We limit employee and agent access to information only to those who have a business or professional reason for knowing, and only to nonaffiliated parties as permitted by law. (For example, federal regulations permit us to share a limited amount of information about you with a brokerage firm in order to execute securities transactions on your behalf, or so that our firm can discuss your financial situation with your accountant or lawyer.)
• We will provide notice of changes in our information sharing practices. If, at any time in the future, it is necessary to disclose any of your personal information in a way that is inconsistent with this policy, we will give
you advance notice of the proposed change so you will have the opportunity to opt out of such disclosure.
• We maintain a secure office and computer environment to ensure that your information is not placed at unreasonable risk.
• For nonaffiliated third parties that require access to your personal information, including financial
service companies, consultants, and auditors, we also require strict confidentiality in our agreements with them
and expect them to keep this information private. Federal and state regulators also may review firm records as permitted under law.
• We do not provide your personally identifiable information to mailing list vendors or solicitors for any purpose.
• Personally identifiable information about you will be maintained during the time you are a client, and for the required time thereafter that such records are required to be maintained by federal and state securities laws. After this required period of record retention, all such information will be destroyed.