Last Updated: December 31, 2013
In order to provide services, we collect and may disclose personal and non-personal information about you to certain providers of services to us. Such information may include name, address, and phone number. In addition, depending on the services requested, we may also collect and may disclose personal and non-personal information, such as date of birth, Social Security number or other identifying numbers (including type, issuer, and expiration date), and any other information necessary to verify and process the request with our service providers, custodians, clearing brokers, and other such entities who process investments and financial transactions for your accounts. Each of these service providers in turn will be required to hold your information private and have their own Privacy Policies in place, which we believe will adequately protect your privacy and/or confidential information from unauthorized access. If you require the names of specific service providers, please feel free to ask us.
We do not disclose nonpublic personal information about our clients, prospective clients, or former clients to anyone, except as permitted by law. The law permits disclosure of nonpublic personal information, for example, where it is necessary to effect, administer, or enforce a transaction requested or authorized by our clients, or in connection with the servicing or processing of a financial product or service requested or authorized by you. The law also permits such sharing where it is released to protect the confidentiality or security of our records pertaining to our clients, the services or products we offer, or the transactions we process or handle. The law also allows for the release of nonpublic personal information to protect against or prevent actual or potential fraud, identity theft, unauthorized transactions, claims or other liability, as well as for resolving client disputes or inquires. The law further allows the release and/or disclosure of nonpublic personal information to comply with federal, state or local laws or regulations or other legal requirements, such as subpoenas or other legal processes. This list of examples of the types of shared information that is permitted by law in not meant to be comprehensive, but to provide you with some basic information about some of the types of sharing permitted by law.
NO SALE OF PERSONAL INFORMATION
We do not sell or exchange your personal information with consumer lists or consumer information bureaus.
SAFEGUARDS TO PROTECT PRIVACY
We take all prudent measures to protect your information. We maintain physical, electronic and procedural safeguards in an effort to secure your nonpublic personal information. When we enter sensitive or private consumer information over the Internet, the information is encrypted and protected. Our database of consumer information resides on servers behind various firewalls to protect against loss, misuse, theft, and unauthorized modification, deletion, or alteration of the information contained in the database.
We have taken preventative measure to restrict access to sensitive data and private information. Only those employees and agents who need to know that information to provide services related to the processing of fund transfers are granted access to personal information. Although our measures conform to those of the industry, we make no claim or warranty as to the security or impenetrability of our system under unusual circumstances or its resilience to future sophisticated attacks.
INFORMATION OF MINORS AND CHILDREN
Our marketing efforts do not knowingly target, collect or use personal information from children under the age of 13. All clients must be 18 or older unless transacting business with us through a parent or guardian as trustee for a trust set up for the benefit of the minor client.
We utilize systems that are provided through internet access. Such systems utilize a standardized encryption process to securely transmit your information through the internet. Some of our service providers grant you access to your account information through their internet portals. We require that these portals have adequate safeguards to prevent unwanted access to your information. Such safeguards could include user identification names and passwords as well as encrypted access and transmission to their websites.
SAFE HARBOR PRINCIPLES
We adhere to the Safe Harbor Principles issued by the United State Department of Commerce and accepted by European Data Protection Authorities for the protection of personally identifiable information and personal data received from the European Union. For further information of Safe Harbor, please go to www.export.gov/safeharbor.