ATON Financial LLC Privacy Policy Effective: March 4, 2021
Our Commitment to You
ATON Financial LLC (“ATON”) is committed to safeguarding the use of your personal information that
we have as your Investment Advisor. ATON (referred to as "we", "our" and "us" throughout this notice)
protect the security and confidentiality of the personal information we have and make efforts to ensure that
such information is used for proper business purposes in connection with the management or servicing of
your account. Our relationship with you is our most important asset. We understand that you have entrusted
us with your private information, and we do everything we can to maintain that trust.
We do not sell your nonpublic personal information to anyone. Nor does ATON provide such information
to others except for discrete and proper business purposes in connection with the servicing and management
of your account as discussed below.
Details of our approach to privacy and how your personal nonpublic information is collected and used are
set forth in this privacy policy.
The Information We Collect About You
You typically provide personal information when you complete the paperwork required to become our
Client. This information may include your:
• Name and address
• Assets
• E-mail address
• Income
• Phone number
• Account balance
• Social security or taxpayer identification number
• Investment activity
• Accounts at other institutions
In addition, we may collect nonpublic information about you from the following sources:
• Information we receive on Brokerage Agreements, Managed Account Agreements and other
Subscription and Account Opening Documents;
• Information we receive in the course of establishing a customer relationship including, but not
limited to, applications, forms, and questionnaires;
• Information about your transactions with us or others
Information about You That ATON Shares
ATON worksto provide products and servicesthat benefit our customers. We may share nonpublic personal
information with non-affiliated third parties (such as brokers and custodians) as necessary for us to provide
agreed services and products to you consistent with applicable law. We may also disclose nonpublic
personal information to other financial institutions with whom we have joint business arrangements for
proper business purposes in connection with the management or servicing of your account. In addition,
your nonpublic personal information may also be disclosed to you, persons we believe to be your authorized
agent or representative, regulators in order to satisfy ATON’s regulatory obligations, and is otherwise
required or permitted by law. Lastly, we may disclose your nonpublic personal information to companies
we hire to help administrate our business. Companies we hire to provide services of this kind are not allowed
to use your personal information for their own purposes and are contractually obligated to maintain strict
confidentiality. We limit their use of your personal information to the performance of the specific service
we have requested.
To repeat, we do not sell your nonpublic personal information to anyone.
Information about Former Investors
ATON does not disclose, and does not intend to disclose, nonpublic personal information to non-affiliated
third parties with respect to persons who are no longer our clients.
Confidentiality and Security
Our employees are advised about the firm's need to respect the confidentiality of our customers' nonpublic
personal information. Additionally, we maintain physical, procedural and electronic safeguards in an effort
to protect the information from access by unauthorized parties.
We'll keep you Informed
We will send you notice of our privacy policy annually for as long as you maintain an ongoing relationship
with us. Periodically we may revise our privacy policy, and will provide you with a revised policy if the
changes materially alter the previous privacy policy. We will not, however, revise our privacy policy to
permit the sharing of nonpublic personal information other than as described in this notice unless we first
notify you and provide you with an opportunity to prevent the information sharing. You may obtain a copy
of our current privacy policy by contacting us at 787-725-6070.
