Privacy Policy

Our relationship with our clients is our most valued asset, and as such, Walthausen & Co., LLC, and its staff are committed to maintaining your trust and confidence in the firm. This is particularly important in the area of protecting non-public information regarding your account. The firm will not disclose details relating to your account to anyone else unless required by law, at your direction, or is necessary in investment advisory role. We will not sell any of your account information to anyone.

Walthausen & Co. collects and maintains information about your account only in providing a discretionary investment management service. The type of information we collect and maintain includes:

  • Details we receive from you in our managed advisory agreement (name, address, other contact information)
  • Data relating to the management of your portfolio (transactions, portfolio holdings, custodian details, restrictions, directed brokerage agreements)
  • Information that we may receive from third parties with respect to your account (custodial statements, actuarial reports)

While Walthausen & Co., LLC has no direct affiliates, the firm may disclose details of your account in limited circumstances, to non-affiliated third party service providers, including:

  • Finance service companies (such as brokers, custodians, and portfolio value and performance verification services, subject to confidentiality agreements)
  • Non-financial service companies that perform services on our behalf (such as IT consultants who maintain our computer systems, subject to confidentiality agreements)

Information may also be disclosed to a fiduciary or representative for your account.

Walthausen & Co. does not disclose non-public information to non-affiliated third parties with respect to accounts no longer managed by the firm.

All of our staff is advised about the requirement to maintain strict client confidentiality. This is also set out in the Duty of Confidentiality section of the Walthausen & Co., LLC “Code of Ethics”.

Access to your account information will only be provided to those persons whose responsibility is to manage and service your account.

We will provide our notice of privacy policy to you annually for as long as you maintain a relationship with us. A copy is available at any time from the Chief Compliance Officer.

12/19/07