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Cayside Partners, LLC Form ADV Part 2 Disclosures
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Cover Page
CAYSIDE PARTNERS, LLC
Form ADV Part 2A
(Firm Brochure)
June 20, 2025
Cayside Partners, LLC
364 Cypress Drive, Suite 202,
Jupiter, FL 33469
Phone | 561-768-9621
Email | tj@Caysidepartners.com
This Form ADV, Part 2A (Brochure) provides information about the qualifications and business
practices of Cayside Partners, LLC (“CSP”). If you have any questions about the contents of this
brochure, please contact us at 561-768-9621 or tj@Caysidepartners.com. The information in this
brochure has not been approved or verified by the United States Securities and Exchange
Commission (SEC) or by any state securities authority. While the firm is in the process of
registering with the SEC, it does not imply a certain level of skill or training on the part of the firm
or its personnel.
References to “we,” “us” and “our” in this Brochure are to CSP. References to “clients” are primarily
to the person(s) that we advise, unless otherwise specified.
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Item 2
Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material changes occur
since the previous release of the Firm Brochure. Each year, we will ensure that you receive a summary
of any material changes to this and subsequent brochures by April 30th. We will further provide you
with our most recent brochure at any time at your request, without charge. You may request a
brochure by contacting us at (561) 768-9621.
Material Changes since the Last Update
Cayside Partners, LLC was established as a new Registered Investment Advisor in June 2020 under the
State of Florida rules and regulations. As of the date of this filing the firm is registering with the
Securities and Exchange Commission.
The following Material changes have been made since the last annual filing on March 15, 2024:
• None
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Item 3
Table of Contents
Item 1 – Cover Page
Item 2 – Table of Contents
Item 3 – Material Changes
Item 4 - Advisory Business
Item 5 – Fees and Compensation
Item 6 – Performance-Based Fees and Side-By-Side Management
Item 7 – Types of Clients
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 – Disciplinary Information
Item 10 – Other Financial Industry Activities and Affiliations
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12 – Brokerage Practices
Item 13 – Review of Accounts
Item 14 – Client Referrals and Other Compensation
Item 15 – Custody
Item 16 – Investment Discretion
Item 17 – Voting Client Securities
Item 18 – Financial Information
Item 19 – Requirements for State Registered Advisors
Part 2A Appendix 1 – Wrap Fee Program Brochure (Not Applicable)
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Item 4
Advisory Business
Cayside Partners, LLC (“CSP”) was launched in 2019 to provide investment advisory services to
clients. CSP is organized as a Limited Liability Company (LLC) with the principal place of business in
Palm Beach/Jupiter, FL. CSP is registering with the Securities and Exchange Commission (CRD#:
306090) as of the date of this filing and owned and operated by Todger Strunk (CRD#: 5161511),
Tanner Strunk (CRD#: 6079179) and Colin Hickey (CRD#: 5803336).
This Disclosure Brochure provides information regarding the qualifications, business practices, and
the advisory services provided by CSP.
Investment Advisory Services
CSP provides investment advisory solutions to individuals, families and businesses (each referred to
as a “client”)
CSP provides investment advisory solutions for its Clients. This is achieved through Client contact
and interaction while providing discretionary and non-discretionary investment management
services. CSP works with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create investment portfolio solutions. CSP will
subsequently recommend a portfolio of assets, including exchange-traded funds (“ETFs”), mutual
funds, individual stocks, bonds and other security types to achieve the Client’s investment goals.
Prior to engaging CSP to provide investment advisory services, each Client is required to enter into
an Investment Advisory Agreement with the Advisor that defines the terms, conditions, authority
and responsibilities of the Advisor and the Client. This allows CSP to better tailor our services to the
individual needs of the client. This may include: 1) Establishing an Investment Policy Statement –
CSP, in connection with the Client, may develop a statement that summarizes the Client’s
investment goals and objectives along with the broad strategies to be employed to meet the
objectives. An Investment Policy Statement generally includes specific information on the Client’s
stated goals, time horizon for achieving the goals, investment strategies, Client risk tolerance and any
restrictions imposed by the Client. 2) Asset Allocation – CSP will develop a strategic asset allocation
that is targeted to meet the investment objectives and tolerance for risk for each Client. 3) Portfolio
Construction – CSP will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client. 4) Investment Management and Supervision – CSP will provide
investment management and ongoing oversight of the Client’s portfolio and overall account.
Retirement Accounts: CSP may provide services to a trustee and/or plan sponsor of a 401k plan or
other Retirement services to assist them in managing their fiduciary responsibilities and other
activities related to their employee retirement plans. In this capacity, we may attend quarterly/annual
meetings, assist in the selection of investments, monitor client’s investments, and participate in
employee communications and education programs, among other activities.
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CSP is a fiduciary under the Investment Advisers Act of 1940, and when we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are also
fiduciaries subject to Title 1 of the Employee Retirement Income Security Act (“ERISA”) and/or the
Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. The
way we make money creates some conflicts with your interests, so we operate under a rule that
requires us to act in your best interest and not put our own interest ahead of yours.
Financial Planning: CSP also provides financial planning consulting services including, but not
limited to, risk assessment/management, investment planning, estate planning, financial organization,
or financial decision making/negotiation.
Family Office Services: CSP also provides Family office services. These services are customizable to
fit the needs of our clients and will vary as they are tailored specifically for each family. Family office
services may include, but are not limited to, consolidated reporting and monitoring, multi-generational
planning, strategic fiduciary services, charitable giving, bookkeeping, risk assessment/management,
financial administration and organization.
Assets Under Management
As of January 31, 2025, CSP has the following assets under management:
Assets Under Management
Assets
Discretionary Assets
$192,301,001
Non-Discretionary Assets
$121,659,127
Total
$313,960,128
As of January 31, 2025, CSP has an additional $138,951,203 in assets under advisement. The firm
manages or advises on a total of $452,911,331.
Clients may request more current information at any time by contacting the Advisor.
Item 5
Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for CSP services.
Each client shall sign an Investment Advisory Agreement that details the responsibilities of CSP and
the Client.
Investment Advisory Services - Investment Advisory Fees can be paid in two different ways,
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either monthly in arrears or quarterly in arrears pursuant to the terms of the Investment Advisory
Agreement. Fees are based on either the market value of the assets on the last business day of the
month or the average monthly balance for accounts billed monthly. For quarterly accounts, the fee
may also be based on the last business day of the quarter or the average quarterly balance pursuant
to the agreement. To the extent that Client engages Advisor any time after the first day of a month,
Client’s fee will be prorated from the date of engagement through the end of the month or quarter.
The maximum Annual Advisory Fee is 1.50%, depending on the amount of assets under
management and the complexity of the Client relationship. Fees may be negotiable at the discretion
of the Advisor. The Client’s fees will take into consideration the aggregate assets under
management with Advisor.
All brokerage commissions, custodial fees, stock transfer fees, transaction fees, charges imposed
directly by mutual, index or exchange-traded funds, fees imposed by variable annuity providers,
certain deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund
fees and other similar charges incurred in connection with transactions for Client’s account imposed
by unaffiliated third parties will be paid out of the assets in the account and are in addition to the
fees paid by Client to Advisor.
Fees are disclosed in full to the client in the client agreement and account opening process which
must be approved, executed and signed by the client. Trading and Account fees are not included in
the advisor fee and charged separately by the exchange broker.
CSP is not able to assign any agreement without client consent.
Financial Planning – Financial planning services are charged in arrears through a fixed fee or
hourly arrangement as agreed upon between the client and CSP. There will never be an instance
where $1,200 or more in fees is charged six or more months in advance. Hourly fees are generally
charged when the scope of services cannot be determined or if the services are limited to one
meeting. Fixed fees are generally quoted to the client for longer term consulting projects. Fees are
negotiable and vary depending upon the complexity of the client situation and the services to be
provided. Hourly fees range from $500 - $1,250 per hour, depending on what is negotiated
between CSP and the client. Similar financial planning services may be available elsewhere for a
lower cost to the client. Fixed fees for longer-term consulting projects range from $5,000 to
$25,000 per project. An estimate for total hours and charges is determined at the start of the
advisory relationship.
Typically, clients will be invoiced monthly for all time spent by CSP as agreed upon by client or
upon completion of the services if less than a month. Clients who wish to terminate the planning
process prior to completion may do so with written notice. The client may obtain a refund of a pre-
paid fee if the advisory contract is terminated before the end of the billing period by contacting
Tanner Strunk at (561) 768-9621. Upon receipt of written notification, any earned fee will
immediately become due and payable, and any prepaid and unearned fees will be immediately
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refunded. A client may terminate an advisory agreement without being assessed any fees or
expenses within five (5) days of its signing.
Family Office Services – Family office service fees are negotiable but range from $25,000 to
$1,000,000 on an annual basis, depending upon the level and scope of the services and the
complexity of the Client relationship.
We offer additional consolidated reporting and monitoring for an annual fee based on total reported
assets. These fees are charged monthly or quarterly pursuant to the agreement. The maximum
Annual Consolidated Reporting and Monitoring Fee is 0.50%. There is not a minimum fee for
consolidated reporting and the basis point fee is negotiable depending on the amount of assets
under management and the complexity of the Client relationship.
Typically, clients will be invoiced monthly or quarterly as agreed upon by the client or upon
completion of the services if less than the agreed upon time period. Clients who wish to terminate
the services may do so with written notice. Upon receipt of written notification, any earned fee will
immediately become due and payable, and any prepaid and unearned fees will be immediately
refunded. A client may terminate an advisory agreement without being assessed any fees or
expenses within five (5) days of its signing.
Item 6
Performance-Based Fees
CSP does not charge performance-based fees for its investment advisory services. The fees charged
by CSP are as described in section 2 above “Fees and Compensation” and are not based upon the
capital appreciation of the funds or securities held by any Client. CSP does not manage any
proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund)
and has no financial incentive to recommend any particular investment options to its Clients.
Item 7
Types of Clients
Cayside Partners, LLC offers its services to individuals or families (private investors, investing their
personal assets) as well as businesses. CSP does not require minimum account sizes for its services.
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
Cayside Partners, LLC is an investment advisory firm that seeks to provide investment solutions that
are consistent with client’s financial goals while preserving and growing capital over the long term.
CSP employs fundamental and technical analysis methods in developing investment strategies for its
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Clients derived from several sources including third party research materials, company activities
(company filings, press releases, etc.), internet sources and unique data models.
Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose
value. Clients should be prepared to bear the potential risk of loss. CSP will assist Clients in
determining an appropriate strategy based on their tolerance for risk and other factors. However,
there is no guarantee that a Client will meet their investment goals. This summary does not attempt
to describe all of the risks associated with an investment in an CSP strategy. We focus heavily on
understanding risks to ascertain the quality of the risk taking and when it is most appropriate to
expose investment capital to risk. We believe risk is best managed by reducing exposure to that risk
when warranted. We believe that the appropriate allocation of assets across diverse investment asset
classes is the primary determinant of portfolio returns and is critical to managing risk and the long-
term success of a client's financial objectives and goals.
While we believe our financial advice is designed to potentially produce risk-managed and
differentiated return profiles, investment objective or goals may not be achieved for a variety of
reasons. Some investment decisions made by CSP may result in loss, which may include the original
principal amount invested. The client must be able to bear the various risks involved in investing,
which may include market risk, liquidity risk, interest rate risk, currency risk or political risk, among
others.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time
horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a
Client's account. Client participation in this process, including full and accurate disclosure of
requested information, is essential for the analysis of a Client's account. The Advisor shall rely on
the financial and other information provided by the Client or their designees without the duty or
obligation to validate the accuracy and completeness of the provided information. It is the
responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio
construction process. CSP typically does not employ any of the below account features, unless
requested by the Client. Following are some of the risks associated with Options, Margin and Short-
Sale transactions:
Options Contracts. Investments in options contracts have the risk of losing value in a relatively
short period of time. Option contracts are leveraged instruments that allow the holder of a single
contract to control many shares of an underlying stock. This leverage can compound gains or losses.
Margin Borrowing. The use of short-term margin borrowings may result in certain additional risks to
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a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in
value, the Client could be subject to a "margin call", pursuant to which it must either deposit
additional funds with the broker or be the subject of mandatory liquidation of the pledged securities
to compensate for the decline in value.
Short Selling. A short sale involves the sale of a security that the Client does not own in the hope of
purchasing the same security at a later date at a lower price. To make delivery to the buyer, the
Client must borrow the security and is obligated to return the security to the lender, which is
accomplished by a later purchase of the security. The Client realizes a profit or a loss as a result of a
short sale if the price of the security decreases or increases respectively between the date of the short
sale and the date on which the Client covers its short position, i.e., purchases the security to replace
the borrowed security. A short sale involves the theoretically unlimited risk of an increase in the
market price of the security that would result in a theoretically unlimited loss.
Other Material Risks Involved
Equity Securities. Investments held by the Unaffiliated Commingled Funds and Managed Accounts
may include long and short positions in common stocks, preferred stocks and convertible securities
of U.S. and non-U.S. issuers; also may invest in depository receipts relating to non-U.S.
securities. Equity securities fluctuate in value in response to many factors, including the activities
and financial condition of individual companies, the business market in which individual companies
compete and general market and economic conditions. Any of these actions could have an adverse
effect on such funds’ ability to achieve its investment objective.
Fixed-Income Securities. The value of fixed-income securities in which an investment fund invests
will change in response to fluctuations in interest rates. For fixed-rate debt securities, when
prevailing interest rates fall, the values of already-issued debt securities generally rise. When interest
rates rise, the values of already-issued debt securities generally fall, and they may sell at a discount
from their face amount. In addition, the value of certain fixed-income securities can fluctuate in
response to perceptions of credit worthiness, political stability or soundness of economic
policies. Valuations of other fixed-income instruments, such as mortgage-backed securities, may
fluctuate in response to changes in the economic environment that may affect future cash flows.
Item 9
Disciplinary Information
Neither Cayside Partners, LLC nor any of its personnel have been the subject of a reportable legal or
disciplinary event.
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Item 10
Other Financial Industry Activities and Affiliations
Neither CSP nor any of our management persons is registered, or has an application pending to
register, as a broker-dealer or a registered representative of a broker-dealer.
Neither Cayside Partners, LLC nor any of its personnel are affiliated with or maintain a material
relationship with another financial industry entity. Our policies require that we conduct business
activities in a manner that avoids actual or potential conflicts of interest between the firm, personnel
and the client, or that may otherwise be contrary to law. We will provide disclosure to the client, prior
to and throughout the term of an engagement, of any conflicts of interest which will or may
reasonably compromise our impartiality or independence.
Item 11
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Cayside Partners, LLC has developed a Code of Ethics Manual that is on file and available to
employees and clients. The key focus of the Code of Ethics is that of a fiduciary; the client always
comes first. The Code of Ethics manual sets forth the basic policies of ethical conduct for all
associated persons of the firm.
We accept the obligation not only to comply with the mandates and requirements of all applicable
laws and regulations, but also to take responsibility to act in an ethical and professionally responsible
manner in all professional services and activities. CSP will provide a copy of our Code of Ethics to
any client or prospective client, upon request.
Neither Cayside Partners, LLC nor any of its personnel are authorized to recommend or effect a
transaction for a client involving any security in which the firm or a related party has a material
financial interest, such as in the capacity as an underwriter, advisor to the issuer, etc.
Additionally, we are prohibited from borrowing from or lending to a client, unless that client is an
approved financial institution or is an immediate family member. In such instances, authorization
for the loan must be granted in advance and documented in writing.
At times personnel and related parties may hold positions in investments that are also recommended
to the client. We may make recommendations or take actions with respect to investments that may
differ in nature or timing from recommendations made to, or actions taken for, other clients or
personnel. However, at no time will the personnel or any related party receive preferential treatment
over the client. Records of all transactions are maintained as required.
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Item 12
Brokerage Practices
Cayside Partners, LLC is not affiliated with any bank, custodian or brokerage firm. CSP does not
recommend custodians to clients. The client is responsible for choosing third party service providers,
such as prime brokerage, custodian and banking, among others. We do not receive any additional
compensation from any third parties when the client engages a brokerage firm or other service
provider.
Our policy is to restrict any non-cash compensation, or soft dollars, that we may receive from a
service provider to only that which enhances our ability to render quality advice and service to the
client. Although we may recommend one or more service providers to the client, we derive no
special benefit from doing so, nor do we “pay up” to receive additional services.
The primary objective in placing orders for the purchase and sale of securities for Client accounts is
to obtain the most favorable net results taking into account factors including price, size of order,
difficulty of execution, confidentiality and skill required of the broker. CSP may aggregate orders in
a block trade or trades when securities are purchased or sold through the same broker-dealer for
multiple (discretionary) accounts. If a block trade cannot be executed in full at the same price or
time, the securities actually purchased or sold by the close of each business day must be allocated in
a manner that is consistent with the initial pre-allocation or other written statement. This must be
done in a way that does not consistently advantage or disadvantage particular Client accounts.
Item 13
Review of Accounts
Cayside Partners, LLC monitors and reviews accounts on a regular basis. Periodic reviews are
scheduled, and Clients may schedule reviews of investments as requested.
Review of Accounts
In addition to the investment monitoring previously noted, each Client account shall be reviewed by,
CSP, at least annually. Reviews may be conducted more or less frequently at the Client’s request.
Accounts may be reviewed as a result of major changes in economic conditions, known changes in
the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account. The
Client is encouraged to notify CSP if changes occur in their personal financial situation that might
adversely affect their investment plan. Additional reviews may be triggered by material market,
economic or political events.
Reports to Investors
Each Client of CSP receives periodic account statements. The Client may also view these reports and
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their account activity through their brokerage’s website. Client brokerage statements will include all
positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide
Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14
Client Referrals and Other Compensation
Cayside Partners, LLC does not receive an economic benefit for providing investment adviser or other
advisory services from any person who is not a Client.
We may engage third-party selling agents to solicit investors for CSP services. In such instances, the
selling agent is typically compensated by way of a retrocession that is specified in the applicable
solicitation or placement agreement. Retrocession is a term used to describe an on -going fee
payable by CSP - to the third-party selling agent so long as such assets placed by the selling agent
remain under CSP advisory. We may pay all or part of our advisory fee to third-party selling agents
for assisting in the placement of interests in CSP. Payment of the retrocession fee does not increase
the fees charged by CSP to any investor. Any solicitation agreement with selling agents is in writing
and in compliance with applicable securities laws.
The payment of retrocessions may cause a selling agent to recommend CSP over another adviser
that does not pay such compensation. In any case in which a selling agent receives payment from
CSP, the selling agent will have a conflict in advising investors with respect to subscriptions and
withdrawals.
Our firm may engage in promoter arrangements for client referrals. These individual promoters
offer our services to the public. The Firm pays a referral fee to the promoter based on a portion of
the management fees charged by the Firm and memorialized in a written agreement if required
(“Promoter Agreement”). In all cases, the Firm will comply with the cash solicitation rules
established by the SEC, state regulators and the client disclosure requirements. If a referred
prospective client enters into an investment advisory agreement with the Firm, a referral fee is paid
to the referring party. The referral relationship will not result in clients being charged any fees over
and above the normal advisory fees charged for the advisory services provided. The Firm will pay
the promoter their share of the total fee. The Promoter Agreement requires that the promoter be
appropriately registered under federal and state securities laws where applicable. Clients receive all
related agreements and disclosures prior to or at the time of entering into an Investment Advisory
Agreement with the Firm.
Some owners of the firm may be engaged in outside business activities involving some clients.
Common ownership in entities for real estate investment and other potential business opportunities
may involve clients of the firm. Activities will be disclosed on the individual ADV 2B disclosure of
each individual. None of these activities involve financial industry related activities or potential
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investments of other clients. The fiduciary standard to all clients will be taken into consideration for
any outside business activities. Clients involved in these activities do not receive any type of
preferential treatment.
Item 15
Custody
Cayside Partners, LLC does not take custody of client cash, bank accounts or securities. The client’s
cash, bank accounts and securities will be maintained by unaffiliated, qualified custodians, such as
banks, brokerage firms, mutual fund companies and transfer agents. CSP does not recommend
custodians to clients. When advisory fees are deducted directly from client accounts at client's
custodian, CSP will be deemed to have limited custody of client's assets and must have written
authorization from the client to do so. Clients will receive all account statements and billing invoices
that are required in each jurisdiction, and they should carefully review those statements for accuracy.
Clients should understand that it is their responsibility to ensure that the fee calculation is correct,
and not the custodian.
Item 16
Investment Discretion
CSP generally has discretion over the selection and amount of securities to be bought or sold in
Client accounts without obtaining prior consent or approval from the Client. However, these
purchases or sales may be subject to specified investment objectives, guidelines, or limitations
previously set forth by the Client and agreed to by CSP. Discretionary authority will only be
authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the
Client's execution of an Investment Advisory Agreement containing all applicable limitations to such
authority. All discretionary trades made by CSP will be in accordance with each Client's investment
objectives and goals.
Item 17
Voting Client Securities
Cayside Partners, LLC does not vote client securities. The client will maintain responsibility for
directing the manner in which proxies are voted, as well as all other elections relative to mergers,
acquisitions, tender offers or other events pertaining to the client’s investments. The client will receive
their proxies and other solicitations directly from the custodian or transfer agent for their investments.
Clients may contact CSP with any questions via phone or in person, regarding any particular
solicitation.
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Item 18
Financial Information
CSP has never filed for bankruptcy and is not aware of any financial condition that is expected to
affect our ability to manage/advise client accounts.
Due to the nature of our services and recent launch of business, an audited balance sheet is not
required, nor included in this disclosure document. Cayside Partners, LLC does not have any
financial conditions that require further disclosure.
Item 19
Requirements for State-Registered Advisers
This section is not applicable as CSP is a SEC registered adviser.
Part 2A Appendix 1 – Wrap Fee Program Brochure (Not Applicable)
Cayside Partners, LLC does not sponsor a wrap fee program, so issues related to a wrap fee program
are not applicable.
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PRIVACY POLICY
CSP has adopted this policy with recognition that protecting the privacy and security of the personal
information we obtain about our customers is an important responsibility. We also know that you
expect us to service you in an accurate and efficient manner. To do so, we must collect and
maintain certain personal information about you. We want you to know what information we
collect and how we use and safeguard that information.
What Information We Collect
We collect certain nonpublic personal identifying information about you (such as your name,
address, social security number, etc.) from information that you provide on applications or other
forms as well as communications (electronic, telephone, written or in person) with you or your
authorized representatives (such as your attorney, accountant, etc.). We also collect information
about your brokerage accounts and transactions (such as purchases, sales, account balances,
inquiries, etc.).
What Information We Disclose
We do not sell, share, or disclose your nonpublic personal information to non-affiliated third party
financial companies. We will not disclose the nonpublic personal information we collect about our
customers to anyone except as necessary as follows: (i) in furtherance of our business relationship
with them and then only to those persons necessary to effect the transactions and provide the
services that they authorize (such as broker-dealers, custodians, independent managers etc.); (ii) to
persons assessing our compliance with industry standards (e.g., professional licensing authorities,
etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided by law.
We are permitted by law to disclose the nonpublic personal information about you to governmental
agencies and other third parties in certain circumstances (such as third parties that perform
administrative or marketing services on our behalf or for joint marketing programs), however we
will not do so. These third parties are prohibited to use or share the information for any other
purpose. If you decide at some point to either terminate our services or become an inactive
customer, we will continue to adhere to our privacy policy, as may be amended from time to time.
Security of Your Information
We restrict access to your nonpublic personal information to those employees who need to know
that information to service your account. We maintain physical, electronic and procedural
safeguards that comply with applicable federal or state standards to protect your nonpublic personal
information.
Changes to our Privacy Policy or Relationship with You
Our policy about obtaining and disclosing information may change from time to time. We will
provide you notice of any material change to this policy before we implement the change.
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