The Firm has adopted certain policies and procedures that address the administrative, technical and physical safeguards for the protection of customer records and information. These policies and procedures are designed to ensure the security and confidentiality of customer records and information, protect against anticipated threats or hazards, and address document destruction as well as unauthorized access to such records or information that may result in harm or inconvenience to our customer.
Collection and Retention of Non-Public Personal Information
We collect and retain information about you to identify and communicate with you, to provide you with products and services you have requested, and to help us respond to your questions.
We collect the following types of non-public personal information about you from the following sources:
- Information we receive about your identity, such as your name, address, social security number, and driver’s license number;
- Information about your transactions with us, our affiliates, and others, such as your account balance; and
- Information that we receive from you on applications, agreements and other forms, such as information about your income and assets.
Disclosure of Non-Public Personal Information
We may disclose non-public personal information about you as necessary to effect, administer, or enforce transactions that you have requested or authorized, or in connection with servicing or processing a financial product or service you have requested or authorized, or to maintain or service your accounts with us, or as otherwise described below. We normally disclose information:
- When it is necessary or helpful in completing a transaction;
- To comply with a law, regulation, legal process or court order which applies to us or to an affiliate;
- When you authorize us to;
- To other companies, financial institutions and networks which may be involved in processing your transactions; and
- To local, state, federal or other regulatory authorities, if we believe a crime may have been committed or as directed and/or required by the authorities.
Except in those limited situations, we will not make any disclosure of information to other companies who may want to sell their products or services to you without your consent. In the event that we intend to disclose information to a third party that is not providing services we will notify all affected clients of such intended disclosure. Each such client will be advised of the nature of the disclosure and given instructions on how to opt out. At present, we have no intention of disclosing information to third parties beyond the necessary disclosures to processors and service providers and as otherwise required by law.
We hope that the use of your information will result in improved client service and responsiveness.