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Important Investor Disclosure Documents
Client Brochure & Privacy Policy

Also known as Form ADV Part 2A, this document is a narrative brochure of disclosures of our firms business practices, fees, conflicts of interest, and disciplinary information.

Customer Relationship Summary

Also known as Form ADV Part 3 or Form CRS, this document is an abbreviated version of the Client Brochure above.

Code of Ethics

Our firm has adopted the CFA Institute's Asset Manager Code of Ethics which governs our duty to be loyal to clients and act in a professional and ethical manner at all times.

Digital Advice Platform Agreement

This document provides the current terms and conditions that governs the relationship with our clients regarding the advisory services provided through our digital advice "robo advisor" platform.

Website Terms and Conditions


Please read these Terms and Conditions ("Agreement", "Terms and Conditions") carefully before using ("the Site") operated by Quartz Partners, LLC ("Quartz","adaptVest", "us", "we", or "our"). This Agreement sets forth the legally binding terms and conditions for your use of the Site at 

By accessing or using the Site in any manner, including, but not limited to, visiting or browsing the Site or contributing content or other materials to the Site, you agree to be bound by these Terms and Conditions. Capitalized terms are defined in this Agreement.

Intellectual Property the Site and its original content, features and functionality are owned by Quartz and are protected by international copyright, trademark, patent, trade secret and other intellectual property or proprietary rights laws.


We may terminate your access to the Site, without cause or notice, which may result in the forfeiture and destruction of all information associated with you. All provisions of this Agreement that by their nature should survive termination shall survive termination, including, without limitation, ownership provisions, warranty disclaimers, indemnity, and limitations of liability.

Links To Other Sites

Our Site may contain links to third-party sites that are not owned or controlled by Quartz Partners, LLC. Quartz Partners, LLC has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third party sites or services. We strongly advise you to read the terms and conditions and privacy policy of any third-party site that you visit.

All content included on this site, such as text, graphics, logos, icons, images, audio/video clips, charts, research, is the property of Quartz and protected by United States and international copyright laws.


Quartz Partners Investment Management, Quartz Partners Retirement Plans, QPIM, adaptVest, adaptCORE, View From the Top, PRICE Analysis Matrix and other adaptVest graphics, logos, page headers, button icons, scripts, and service names are trademarks or trade dress of adaptVest. adaptVest trademarks and trade dress may not be used in connection with any product or service that is not Quartz, in any manner that may cause confusion among clients, or in any manner that disparages or discredits adaptVest. All other trademarks not owned by adaptVest that appear on this site are the property of their respective owners, who may or may not be affiliated with, connected to, or sponsored by adaptVest.


"Cookies" are small files used by websites to store information on Your computer that provide technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on our website. adaptVest cookies contain information that identifies You during a session and allows the software to function, to facilitate site navigation, and to personalize Your experience. For the Services to work properly, Your browser must be enabled to accept cookies. adaptVest may also use anonymous log file information to: (a) make the websites better, faster and more robust; (b) monitor statistics relating to the websites; and (c) police the websites and enforce the terms of use and any other guidelines for usage. This information is also not for sale. We do not use cookies to pull data from Your hard drive or view data in cookies created by other websites. Third parties may view, edit, or set their own cookies. The use of these technologies by third parties is subject to their own privacy policies and is not covered by this Privacy Policy, except as required by law.

A cookie is a small text file downloaded to an individual’s computer (or other device) when accessing webpages that use them. Cookies and other online tracking technologies (collectively referred to in this policy as “cookies”) allow a website to store and retrieve information about visitors’ online activity. Cookies are, for example, how a website remembers what display language you chose or what items you put into your online shopping cart.

Cookies can be categorized by who places them:

  • First-party cookies: These cookies are downloaded to an individual’s computer from a server or domain managed by the publisher of the website whose service the individual is requesting.

  • Third-party cookies: These cookies are downloaded to a computer from a server or domain that is not managed by the publisher, but by another entity that may be seeking data obtained through cookies.

Cookies can also be categorized by their duration:

  • Session cookies: These cookies are designed to collect and store data while the individual accesses a web page. They are often used to store information for the duration of a visit to the site (e.g., what account you are logged into). Once an individual leaves the website, the session cookie is deleted.

  • Persistent Cookies: These cookies store data on a computer for the duration of the period set within the cookie’s file, which is determined by the entity controlling the cookie, and can range from a few minutes to several years, or until manually deleted.

Lastly, cookies can be categorized by the function they serve. Fisher Investments uses the following types of first- and third-party cookies:


  1. Functionality Cookies:These cookies allow the website to remember choices you make (such as your geographic region or preferred text size). Functionality cookies do not collect any personal information. Enabling functionality cookies may be necessary to access the full content of website material.

  2. Personalization Cookies: Personalization cookies allow a website to remember information that changes the page’s appearance or behavior, such as, for example, the language selected for viewing the page.

  3. Analytics Cookies: Analytics cookies analyze how individuals browse a website and enable Quartz to measure the number of visitors to its websites, as well as to measure and analyze how individuals interact with the site. We use this information to improve the websites and the products or services offered.

  4. Behavioral Advertising Cookies: Quartz serves advertisements on various websites using third party companies. If an individual visits a website or clicks on one of Quartz advertisements, behavioral cookies will be placed on the individual’s computer. Behavioral cookies allow Quartz to manage and optimize its digital marketing (e.g., banner ads, pages offering informational brochures, email campaigns, etc.). Behavioral cookies may be used to build a profile to provide content more relevant to an individual’s interests. They adapt advertising and the content the individual sees on other websites based on browsing habits, including how the individual navigates websites, as well as how the individual interacts with internet advertising.

Do Not Track" Signals: Our website does not respond to "do not track" signals from user's web browser.

How to Manage Cookies: To learn more about behavioral advertising cookies and to opt in or out of multiple advertising networks at once, you can visit the website YourAdChoices. Some advertising networks do not participate in the YourAdChoices service. To opt out of some of these networks, please visit the consumer opt-out page of the Network Advertising Initiative.

As explained above, cookies help you to get the most out of the websites that make use of this technology. Disabling cookies may affect the functionality of many of the websites you visit. If you do disable cookies, performance and functionality will be affected. If you wish to delete, disable, or re-enable cookies, you may do so through your browser by using a 'help' function in the browser or contact the browser provider (e.g., Chrome, Microsoft Edge, Safari, Firefox).​

Limited License

Quartz  grants you a non-exclusive, non-transferable, limited license to use the Site in accordance with this Agreement.

Limitation Of Liability

In no event shall Quartz, nor its directors, employees, partners, agents, suppliers, or affiliates, be liable for damages, direct or consequential, resulting from your use of the Site, and you agree to defend, indemnify and hold us harmless from any claims, losses, liability costs and expenses, including but not limited to attorney's fees, arrising from your violation of any third-party's rights.

Warranty Disclaimer

Your use of the Site is at your sole risk. The Site is provided on an "as is" and "as available" basis. The Site is provided without warranties of any kind, whether express or implied, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, non-infringement or course of performance. Quartz, its subsidiaries, affiliates, and its licensors do not warrant that a) the Site will function uninterrupted, secure or available at any particular time or location; b) any errors or defects will be corrected; c) the Site is free of viruses or other harmful components; or d) the results of using the Site will meet your requirements.

Governing Law

This Agreement (and any further rules, polices, or guidelines incorporated by reference) shall be governed and construed in accordance with the laws of New York, United States, without giving effect to any principles of conflicts of law.

Changes To This Agreement

We reserve the right, at our sole discretion, to modify or replace these Terms and Conditions by posting the updated terms on the Site. Your continued use of the Site after any such changes constitutes your acceptance of the new Terms and Conditions.Please review this Agreement periodically for changes. If you do not agree to any of this Agreement or any changes to this Agreement, do not use, access or continue to access the Site or discontinue any use of the Site immediately.


If you have any questions about this Agreement, please contact us.

Investment Disclosures​

Quartz Partners is under common ownership and control with Etico Partners, LLC a registered broker-dealer (Member FINRA/SIPC). The entities share office space and personnel and are affiliated through common ownership and control. Additional disclosures and regulatory information about our firm is available on the SEC’s website at by either searching by our firm name or unique identifying CRD #174327. The use of the term “registered investment adviser” or being “registered” with the SEC, any state securities authority or self regulatory organization does not imply a certain level of skill or training. Quartz Partners, LLC ("Quartz", "adaptVest", "us", "we", or "our") provides a digital investment advice service called adaptVest and is recommending that investors should carefully consider the underlying funds’ fees, expenses, objectives and risks carefully before investing. adaptVest puts forth its best effort to achieve the objectives of its strategies. However, there is no guarantee that the objectives will be achieved. An Account's return and principal will fluctuate so that the Account, when redeemed, may be worth more or less than the amount in the Account at or subsequent to the effective date of the Investment Management Agreement. All results are expressed in US dollars and reflect reinvestment of dividends, capital gains, and other earnings as well as the deduction of trading or other expenses incurred. Performance reflects the gross return of the composite reduced by the maximum annual fee of 2%. Actual fees paid and performance may vary based on factors including account size, custodian, contributions and withdrawals, which may cause your returns to differ from those listed in this report. In particular, accounts held at variable annuities and/or fund families will have performance that frequently deviates from the listed data due to fees and investment options. Please contact adaptVest or your custodian for your specific performance information. adaptVest strategies may involve above-average portfolio turnover, which could negatively impact the net after-tax gain experienced by an individual client. Performance results do not reflect the impact of taxes. Investments in the programs are subject to investment and manager risk, which carry the potential for a loss of principal. Tactical management strategies do not protect against losses in declining markets and there is no guarantee that the strategy performance will meet or exceed the listed benchmark. adaptVest’s risk management process includes an effort to monitor and management risk, but should not be confused with and does not imply low risk.


High yield bonds may be subject to greater market fluctuations, risk of default or loss of income and principal than higher rated securities. The use of leverage strategies by a fund increases the risk to the fund and magnifies gains or losses on the investment. You could incur significant losses even if the long-term performance of the underlying index showed a gain. Most leveraged funds “reset” daily. Due to the effect of compounding, their performance over longer periods of time can differ significantly from the performance of their underlying index or benchmark during the same period of time. Inverse index funds experience losses when the underlying benchmark rises. The benchmarks referenced herein have not been selected to represent an appropriate benchmark with which to compare a client’s performance, but rather are disclosed to allow for comparison of the client’s performance to that of certain well-known and widely recognized indices. Indexes are unmanaged, do not incur management fees, costs and expenses, and cannot be invested in directly. The S&P 500 Index is a market capitalization-weighted index of 500 widely held stocks often used as a proxy for the stock market. It is the most widely used benchmark for US stock funds and portfolios. The Barclays Capital U.S. Aggregate Bond Index is comprised of approximately 6,000 publicly traded bonds including U.S Government, mortgage-backed, corporate, and Yankee bonds with an approximate average maturity of 10 years.


adaptVest is an investment adviser registered with the SEC under the Investment Advisers Act of 1940. SEC registration does not constitute an endorsement of the firm by the SEC nor does it indicate that the advisor has attained a particular level of skill or ability. adaptVest’s Form ADV Part 2: Firm Brochure and other account documentation are available upon request. adaptVest may pay a portion of the annual advisory fee to a solicitor who is responsible for introducing an investor to adaptVest. adaptVest claims compliance with the Global Investment Performance Standards (GIPS®). A complete list and description of the firm’s composites and a presentation that adheres the GIPS® standards are available upon request. 

Email Terms and Conditions

Emails, including attachments, may include non-public, confidential or legally privileged information. If you are not an intended recipient, you are hereby notified that any dissemination, distribution or copying of the information contained in or transmitted with this e-mail is unauthorized and strictly prohibited. If you have received this email in error, please notify the sender by replying to this email and permanently delete this e-mail, its attachments, and any copies of it immediately. Information in emails is not warranted as to completeness or accuracy. Further, since the confidentiality of email cannot be guaranteed, please do not include private or confidential information in your email communications. Emails are subject to regulatory and supervisory, and law enforcement review. Email transmission cannot be guaranteed to be secure or error-free. All information within emails is subject to change without notice. Any comments or statements made herein do not necessarily reflect those of the company.

IRS Circular 230 Disclosure

Please be advised that any discussion of U.S. tax matters contained within this communication (including any attachments) is not intended or written to be used and cannot be used for the purpose of (i) avoiding U.S. tax related penalties or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.

Social Media
Social Media Disclaimer

We nor our affiliates have control over third-party sites such as Twitter. Your use of third-party sites is governed by the terms of use and privacy and security policies applicable to such sites. Your use of any third-party sites or content is done at your own risk. We may provide links to third-party sites and content as a convenience. The existence of any such link does not constitute an endorsement by our company of the linked third-party site or content.


Content attributed to “@quartzinvest” and "@KyleWebberPM" refers exclusively to the opinions of our firm. This material is for informational and educational purposes only as of the date of writing and may change at any time based on market or other conditions. The material is not intended to be relied upon as investment advice or recommendations, does not constitute a solicitation to buy or sell securities and should not be considered specific legal, investment or tax advice. The information provided does not take into account the specific objectives, financial situation, or particular needs of any specific person. All investments carry a certain degree of risk and there is no assurance that an investment will provide positive performance over any period of time.

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