Policies
SKY Investment Group LLC (the “Company”) will collect information, such as name, address, Social Security or tax identification numbers, date of birth, current investment holdings, investment history, risk tolerance and other personally identifiable financial information from its clients during the ordinary course of business (“Nonpublic Personal Information” or “NPI”). The Company protects the confidentiality of NPI in the Company’s possession from improper disclosure by maintaining and enforcing policies, as well as physical and electronic safeguards, against the release of such information. Unlawful disclosure of NPI is prohibited, and access to NPI is limited to Company personnel. Nonpublic Personal Information in the Company’s possession, including tax identification and Social Security numbers, may only be released when allowed or required by law [or to third party service providers in connection with administrative, compliance, tax or regulatory matters] or, in the case of information regarding a client of the Company, when authorized by the client, or when allowed or required by law.
All Nonpublic Personal Information is used for the purpose of creating and maintaining an investment portfolio designed to meet the investment goals within a client’s risk tolerance level. NPI is provided to custodians after the customer has completed a new account form for the appropriate custodian. This form constitutes written consent by the client. All employees and nonaffiliated third parties who are given access to NPI are required to sign a confidentiality agreement at the beginning of said employees’ employment or nonaffiliated third parties’ engagement.
Nonpublic Personal Information is not disclosed to non-employees other than as described above unless specifically authorized and requested by the client, such as to persons preparing client tax returns, trusts or wills.
SKY Investment Group LLC does not sell client lists and, other than as described above, will not disclose or disseminate Nonpublic Personal Information for any purpose not directly related to the provision of investment advisory services.
All Nonpublic Personal Information will be maintained for a period of at least six years past the termination of the client relationship. Any NPI that is determined to be eligible for destruction will be disposed of by a third-party company professionally engaged for the express purpose of handling confidential information. Routers installed on the Company’s computer system will provide protection of NPI stored electronically.
Clients will be informed of the Company’s privacy policy annually.
By accessing SKY Investment Group LLC’s website, the user acknowledges that the Company collects aggregate data commonly known as “cookies.” This information is used for statistical purposes only and will not be used to identify individual users.
Questions about the foregoing should be directed to William Newman at bnewman@skyig.com.
Reviewed October 2024
SKY Investment Group LLC
One Financial Plaza, Suite 1210
Hartford, CT 06103
(860) 761-9700
Cybersecurity Risk Management
SKY Investment Group recognizes the importance of safeguarding client data and maintaining robust cybersecurity protocols. We continually assess and strengthen our digital infrastructure to prevent unauthorized access and data breaches.
Our Cybersecurity Practices
Routine vulnerability assessments and penetration testing
Endpoint protection and threat detection systems
Secure client communications via encrypted channels
Staff training on cybersecurity awareness and incident response
Incident Management
In the event of a cybersecurity incident, we follow an established response plan that includes prompt notification to affected clients, regulatory reporting, and remediation steps to contain and resolve the issue.
Ongoing Commitment
Our cybersecurity policies evolve in response to emerging risks, regulatory guidance, and industry best practices. We remain committed to transparency, resilience, and protecting your personal information.