Disclosures

IMPORTANT DISCLOSURE INFORMATION

The Swarthmore Group, Inc. (Company”) is an SEC registered investment adviser located in Philadelphia, Pennsylvania.    Company may only transact business in those states in which it is registered, or qualifies for an exemption or exclusion from registration requirements.  Company’s web site is limited to the dissemination of general information pertaining to its advisory services, together with access to additional investment-related information, publications, and links.  Accordingly, the publication of Company’s web site on the Internet should not be construed by any consumer and/or prospective client as Company’s solicitation to effect, or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, over the Internet.  Any subsequent, direct communication by Company with a prospective client shall be conducted by a representative that either is registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides.  A copy of Company’s current written disclosure Brochure discussing Company’s business operations, services, and fees is available from Company upon written request.  Company does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to Company web site or incorporated herein, and takes no responsibility therefore.  All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.

Please remember that different types of investments involve varying degrees of risk, and there can be no assurance that the future performance of any specific investment or investment strategy (including those undertaken or recommended by Company), will be profitable or equal any historical performance level(s).

Certain portions of Company’s web site (i.e. newsletters, articles, commentaries, etc.) may contain a discussion of, and/or provide access to, Company (and those of other investment and non-investment professionals) positions and/or recommendations as of a specific prior date.  Due to various factors, including changing market conditions, such discussion may no longer be reflective of current position(s) and/or recommendation(s).  Moreover, no client or prospective client should assume that any such discussion serves as the receipt of, or a substitute for, personalized advice from Company, or from any other investment professional.  Company is neither an attorney nor an accountant, and no portion of the web site content should be interpreted as legal, accounting or tax advice.

PRIVACY AND DATA PROTECTION POLICY

The Swarthmore Group is committed to protecting the confidentiality and security of your information.  As required by law, this notice has been provided to you to describe how we maintain the information we gather from and about you and the situations under which we may need to share it. 

Q: What type of information does The Swarthmore Group collect and how do we use it?

A: As an investment advisor, we obtain information about you upon the application for our financial products and services, and as we perform our duties as an investment advisor.

We limit the collection and use of information within our firm to only those individuals associated or employed with us that must have information to provide financial services to you.  Such services include establishing and maintaining your accounts, processing transactions, complying with legal and regulatory requirements, and other services described in our Form ADV.

Q: How does The Swarthmore Group share this information?

 A: We do not sell, rent or otherwise disclose information obtained in the course of our practice without your consent except as required or permitted under law. Permitted disclosures include, for instance, providing information to unrelated third parties who need to know such information in order to assist us in providing services to you.  Unrelated third parties may include broker/dealers, insurance companies, and the custodian with which your assets are held.  In such situations, we require these third parties to treat your private information with the same degree of confidentiality as we do. 

Q: How does The Swarthmore Group safeguard your information?

A: The Swarthmore Group protects your information from vulnerability and unauthorized use by restricting access to your personal information to those employees that require the information to provide you with products and services. These employees may access information only when there is an acceptable reason to do so, such as to service your account or provide you with financial services.  Employees who violate our Privacy Policy are subject to disciplinary action up to and including termination from employment. 

In addition to maintaining physical and procedural safeguards,  we use a variety of security technologies and operational functions to protect your information.  However,  due to the increasingly sophisticated strategies of today’s cyber terrorists, please be advised that the perfect network security does not exist.  Although The Swarthmore Group continually reevaluates our security measures to combat any potential risks and threats to our system, The Swarthmore Group does not warrant that its information is impenetrable or invulnerable to hackers.   

Q: How does The Swarthmore Group inform clients about its Privacy Policy?

A: We send our Privacy Policy to new clients when they open a new account. We also send the policy to current clients yearly.  We may revise this privacy notice.  If we make any material changes, we will notify you as required by law. 

Q: How does this Privacy Policy apply to former clients?

A: Even if we cease to provide you with financial services, our Privacy Policy will continue to apply to you and we will continue to treat your non-public information with strict confidentiality.

If you have any questions regarding our Privacy  Policy, or should you require additional information, please contact Denise Caruso, Chief Compliance Officer, at 215.557.9300 or via email at dcaruso@swarthmoregroup.com.   A copy of our ADV is available upon request.  

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