Client Privacy Policy

Cooke & Bieler has always safeguarded, and will continue to vigilantly safeguard, each client’s privacy from unauthorized access to the personal information to which the client has entrusted with us. Above all, this means the firm will not sell any personal information to any third parties without the client’s consent. Further, Cooke & Bieler will not share or disclose any personal information about you or your account with third parties unless: Cooke & Bieler receives your prior written consent; we believe the recipient is your authorized representative; we believe we are required by law to disclose information to the recipient; you have directed us to disclose the information to the recipient; or we believe the disclosure is necessary in order to provide you with Cooke & Bieler’s services.

Cooke & Bieler collects and maintains personal information from clients, clients’ legal representatives, and clients’ custodian banks, so we can provide investment management services to the client. The information we collect and maintain about clients, depending on the specific facts and circumstances of the relationship, includes:

   - Name, address and phone number

   - Social security or tax identification number

   - Custodial account numbers

   - Assets

   - Income

   - Investment activity

This personal data, as well as any ancillary information that may come into Cooke & Bieler’s possession during the course of normal business (such as brokers who execute trades on your behalf), will be used by Cooke & Bieler for purposes of opening and maintaining account information, facilitating smooth flow of executing orders, and maintaining your investment portfolio.

In addition, our Internet Privacy Policy applies to information we receive from our website www.cooke-bieler.com and from incoming email. We do not collect personally identifiable information about you when you visit our website, unless you voluntarily provide it to us by completing the “Contact Us” page or by sending us an email. If you choose to share with us personally identifiable information using either of these methods, we will retain it in our electronic communications archive. Customer SMS consent and phone number will not be shared with third parties.

Even if you do not share personally identifiable information with us, our website still may collect some information about you that does not personally identify you. We are not unique in this regard, as this is a common practice of many businesses’ websites. For example, we use a service provider to gather the following information: internet addresses that bring visitors to our website, IP addresses of visitors to our website, statistics about which pages on our website are most often visited, dates and times our website is visited, how long visitors remain on each page, general geographic information about website visitors, types of browsers and devices used to access our website, etc. Our service provider uses cookies to collect this data and provides us with statistics in an aggregated format. We use these statistics in our ongoing efforts to improve our website. If you want to prevent cookies from being set on your device or to opt-out of this type of data collection, you can change your internet browser’s configuration or settings.

To maintain our privacy commitment at Cooke & Bieler, we have instituted firm-wide practices to safeguard the information that we maintain about our clients. We have implemented policies and procedures, including a data breach incident response program, that address administrative, technical, and physical safeguards for the protection of your records and personal information. Should a data breach incident occur in which your sensitive personally identifiable information has been, or is reasonably likely to be, used in a manner that would result in substantial harm or inconvenience to you, we will notify you as soon as reasonably practicable but not later than 30 days after we have become aware of the incident.

As Cooke & Bieler strives to maintain our obligations to comply with federal laws and any applicable state laws and to continue to protect client privacy, Cooke & Bieler will deliver our current policy to clients on an annual basis, unless we have made no changes to our policies and practices regarding disclosure since our last policy delivery. Should the relationship become inactive in the future, we will continue to protect a client’s personally identifiable information in the same manner as when the client relationship was active.