The purpose of this Privacy Statement is to outline the privacy policies and procedures of Badgley Phelps and certain information-sharing arrangements.

1. Sources of Information about our Clients.

Badgley Phelps collects nonpublic personal information about our clients from the following sources:

  • Information we receive from our clients on applications and other forms, in discussions with our clients, via electronic mail, and other interactions;
  • Information we receive from our clients’ other advisors, as directed by our clients, such as their accountants, attorneys and trustees; and,
  • Information about our clients’ transactions and assets, from client custodians, brokers, bankers and others.

2. Disclosure of Information about our Clients.

The confidentiality of our clients’ personal and account information always has been a priority at Badgley Phelps. We do not disclose any nonpublic personal or account information about our clients except as permitted or required by law and except as otherwise outlined below. Badgley Phelps maintains physical, electronic, and procedural safeguards to guard our clients’ nonpublic personal and account information. Due to the small size of our staff and the team approach employed in providing services to our clients, Badgley Phelps’ employees generally have access to client account and basic personal information.

We do not rent or sell personal information and will only share personal information:

  1. When we receive your consent or when we reasonably believe the recipient is your authorized representative (i.e., attorney, CPA, trustee, etc.);
  2. When it is necessary to provide you with services and fulfill our obligations with non-affiliated companies that provide processing, account maintenance and related services in connection with your investments and transactions handled by us; and
  3. When we are required by law to fulfill legal or regulatory requirements.

If our clients decide to close their account(s) or become an inactive client, we will adhere to the privacy policies and practices as described in this statement.

3. Additional Information.

If you would like additional information about Badgley Phelps’ privacy policies and procedures, please contact your investment manager or our firm’s Chief Compliance Officer.