OSA Disclosure Documents

Privacy Policy

O’Keefe Stevens Advisory, Inc., a registered investment advisory and financial planning
firm, is committed to safeguarding the confidential information of its clients. We hold all
personal information provided to our firm in the strictest confidence. The records we
maintain include all personal information that we collect from you in connection with any
of the services provided by O’Keefe Stevens Advisory. We have never disclosed
information to non-affiliated third parties, except as permitted by law, and do not
anticipate doing so in the future. If we were to anticipate such a change in our Firm’s
policy, we would be prohibited under the law from doing so without advising you first.
As you know, we use health and financial information that you provide to us to help you
meet your personal financial goals and have established the following procedures to
mitigate any real or perceived infringements of your rights of privacy:

• We limit access to your information by our associated persons to only: 1) those
who have a business or professional reason for knowing; 2) non-affiliated parties
as permitted or required by law (For example, federal regulations permit us to
share a limited amount of information about you with a brokerage firm in order to
execute securities transactions on your behalf, or so that our firm can discuss
your financial situation with your accountant or attorney.); or 3) those required by
judicial or regulatory process.

• We maintain a secure office and computer environment to ensure your
information is not placed at unreasonable risk.

• The categories of non-public personal information that we collect from clients
depend upon the scope of the client’s engagement. It will include information
about your personal finances, information about your health to the extent that it is
needed for the planning process, information about transactions between you and
third parties and information from consumer reporting agencies, if obtained.

• For unaffiliated third parties that require access to your personal information,
including financial services companies, consultants and auditors, we also require
strict confidentiality in our agreements with them and expect them to keep this
information private. Federal and state regulators may also review Firm records as
permitted by law.

• The disclosure information contained in any document completed by the client for
processing and/or transmittal by O’Keefe Stevens Advisory in order to facilitate
the commencement, continuation or termination of a business relationship
between the client and a non-affiliated third party service provider (i.e.,
broker/dealer, investment advisor, account custodian, insurance company, etc.),
including information contained in any document completed and/or executed by
the client for O’Keefe Stevens Advisory (i.e., advisory agreement, Investment
Policy Statement, other client information form, etc.), shall be deemed as having
been automatically authorized by the client with respect to the corresponding
non-affiliated third party service provider.

• We do not provide personally identifiable information to mailing list vendors or
solicitors for any purpose, at any time. Personally identifiable information about
you will be maintained during the time you are our client, for the required time
thereafter that such records are required to be maintained by federal and/or state
securities laws and regulations and consistent with the CFP Board Code of Ethics
and Professional Responsibility. After this required period of record retention, all
such information will be destroyed.

• Recognizing the expanded use of Internet and technology-based devices in
providing advisory services to clients, O’Keefe Stevens Advisory is committed to
protecting your personal information from unauthorized access or use through
these avenues. We seek to use reasonable organizational, physical, technical and
administrative measures to protect personal information within our organization.
Unfortunately, no data transmission or storage system can be guaranteed to be
100% secure. If at any time you have reason to believe that your interaction with
us may have been compromised or is no longer secure, please immediately
contact Peter S. O’Keefe, our Firm’s Chief Compliance Officer. Your concerns
will be promptly investigated and you will be notified of the results.

• You also have a responsibility to help us protect your accounts by never revealing
your user name or password to other individuals. In order to help us protect your
personal information, it is important that you always keep your account
information safe. Never share your personal ID, passwords or PINs with anyone,
under any circumstances.

• In providing advisory services to you, O’Keefe Stevens Advisory may, in the
context of certain telephone and/or in-person discussions, request your full Social
Security number, account number or other information to verify your identity
before conducting actions you have requested. For example, we may ask for such
information to verify your identity when you place a call to us or when we call
you. To aid in preventing identity theft, however, we will never request that you
disclose your personal IDs, passwords or PINs under any circumstances.
Additional information regarding identity theft and the steps you can take to help
protect yourself from fraud can be found on the Federal Trade Commission
website, www.ftc.gov.

O’Keefe Stevens Advisory Form ADV Part 2A & Part 3 (Form CRS)

O’Keefe Stevens Advisory Brochure ADV Part 2B.pdf


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