ANOVA Management Inc.
Privacy Policy
Effective: November 4, 2025
Our Commitment to You
ANOVA Management Inc. (referred to as “we”, “our”, “us”, and “ANOVA” throughout this document) is committed to safeguarding the use of your personal information that we have as your Investment Advisor. ANOVA protects 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 non-public personal information to anyone. Nor does ANOVA 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 non-public 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 non-public 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; and
- Information about your transactions with us or others
Information about You That We Share
ANOVA works to provide products and services that benefit our customers. We may share non-public 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 non-public 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 non-public personal information may also be disclosed to you, persons we believe to be your authorized agent or representative, regulators in order to satisfy ANOVA’s regulatory obligations, and is otherwise required or permitted by law. Lastly, we may disclose your non-public 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 non-public personal information to anyone.
Information About Former Clients
ANOVA does not disclose, and does not intend to disclose, non-public 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’ non-public personal information. Additionally, we maintain physical, procedural and electronic safeguards in an effort to protect the information from access by unauthorized parties. However, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your device and account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Third-Party Links
Our website contains links to third-party websites, including those of affiliates. Any access to and use of such linked websites is not governed by this privacy policy but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third-party websites.
We 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 non-public 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 (713) 459-5254.