Regulatory Disclaimers

Link to Firm ADV Part IIA

Privacy Policy

GT Investment Management (“us”, “we”, or “our”) operates the gtria.com website (the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from GrowthinkCapital.com

Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you.

When you purchase something from GT Investment Management, we collect the personal information you give us – such as your name, address and email address – in order to both fulfill and support the products you purchase.

Email marketing: With your permission, we may send you emails about new products, free and premium content (i.e. blog posts, reports/whitepapers, etc.), and special events.

Consent

When you provide us with personal information – to complete a transaction, verify your credit card, place an order, or return a purchase – we imply that you consent to our collecting it and using it for that specific reason only.

If we ask for your personal information for a secondary reason (i.e. newsletter subscription and marketing messages), we will ask you directly for your expressed consent and provide you with an opportunity to withdraw your consent.

You may withdraw your consent at any time by clicking on an “unsubscribe” link which is offered at the bottom of every email we send.

You may also withdraw your consent anytime, by contacting us at 1-800-810-7068.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • First name and last name
  • Phone number
  • Address, State, Province,IP/Postal code, City
  • Cookies and Usage Data

Usage Data

We may also collect information about how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

Use of Data

GT Investment Management uses the collected data for various purposes:

  • To complete a transaction, verify your credit card, place an order, or return a purchase
  • To provide and maintain the Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer care and support
  • To provide analysis or valuable information so that we can improve the Service
  • To monitor the usage of the Service
  • To detect, prevent and address technical issues

Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Storage of Data

Our shopping cart solution is hosted and managed by Infusionsoft. They provide us with the online e-commerce platform that allows us to sell our products and services to you.

Your data is stored through Infusionsoft’s data storage, databases and the general Infusionsoft application. They store your data on a secure server behind a firewall.

GT Investment Management will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure Of Data

Legal Requirements

GT Investment Management may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of GT Investment Management
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security Of Data

We have internal procedures that limit access to customer information to only those members who are considered “authorized” personnel.

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Transfer

In the event of a transfer of ownership of our firm, such as acquisition by or merger with another company, we will provide notice before any personally identifying information is transferred and becomes subject to a different privacy policy.

Analytics

We use a tool called “Google Analytics” to collect information about use of this site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use (as amended for government websites) and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

IMPORTANT: We do not sell, rent or otherwise disclose your personal information to any third parties, including but not limited to advertisers, strategic partners or vendors.

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Questions About Our Privacy Policy

If you have any questions about this Privacy Policy, please contact us.

US Patriot Act Notification

In the global marketplace, the attempted use of financial institutions to launder money is a significant problem that has caused great concern in the international and domestic community, which has resulted in the passage of strict laws and increased penalties for money laundering worldwide.

While the U.S. has had strong anti-money laundering laws applicable to certain financial institutions, including banks, broker-dealers and investment advisors, those laws have recently been strengthened and extended to other financial institutions including stand-alone futures commission merchants, commodity trading advisors, commodity pool operators, and precious metals dealers and refiners. Among other things, the USA PATRIOT Act requires all these financial institutions to establish anti-money laundering compliance programs, which include internal policies, procedures and controls designed to detect and prevent money laundering. The new requirements include enhanced “know your customer” obligations (e.g., verification of customer identity), monitoring and reporting suspicious transactions, special due diligence checks for certain customers, ongoing employee training, record keeping and independent audits to test the programs. GT Investment Management, LLC (“GTIM”) have established policies and procedures to protect it from being used to launder money. All GTIM employees must be vigilant in the fight against money laundering and must not allow our Investment Advisory to be used for money laundering activities.

Reporting of Cash Transactions
Federal law imposes reporting requirements for certain transactions involving cash or cash- equivalent instruments (e.g., travelers checks, money orders, cashier’s checks). In general, transactions involving the deposit, withdrawal or exchange of more than $10,000 in currency in a day must be reported to the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the
U.S. Treasury Department, by filing a Currency Transaction Report. Multiple transactions are treated as a single transaction if they total more than $10,000 during any one-business day, and must be reported.

Customer Identification
Federal law requires that financial institutions establish “know your customer” policies and procedures. These requirements are one borne of sound business practices and established regulatory oversight. Presently, industry regulations require firms to undertake reasonable efforts to obtain and maintain the essential facts relative to each customer and each account opened. For ease of use, this information is captured and maintained in the firm’s account documentation, which includes the customer account application, Form W-9 (Request for Taxpayer Identification Number and Certification), corporate resolutions (if applicable), governmental photo identification (e.g., driver’s license, passport, national identity card) or other such documentation as may be appropriate to ascertain and verify a person’s identity. Additionally, the firm may verify customer information using various electronic databases such as Equifax/CDC, Dunn & Bradstreet and the like. The process of “knowing” one’s customer is not concluded once the initial account opening information has been obtained. Even after the account is established, employees are required to update customer’s information in the normal course of the relationship.

Business Continuity Planning

GT Investment Management has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us – If after a significant business disruption you cannot contact us as you usually do at (310) 954-2013 you should call our alternative number (213) 927-3969.

Our Business Continuity Plan – We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Varying Disruptions – Significant business disruptions can vary in their scope, such as to only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within 3 days. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within 14 days. In either situation, we plan to continue in business and notify you how to contact us.

For more information – If you have questions about our business continuity planning, you can contact us at info@gtria.com or (310) 954-2013.