As a registered investment adviser, we are covered under the definition of a “financial institution” under the Gramm-Leach-Bliley Act (“The Act”). We are held to similar privacy rules such as those associated with the SEC’s Privacy Rule (“Regulation S-P”), to which many states defer in whole or in part. The privacy rules require every broker, dealer, investment company, and registered investment adviser to adopt policies and procedures reasonably designed to safeguard customer records and other non-public consumer information. An advisor’s privacy policy must protect prospective, current, and former clients.
We utilize information that you provide in order to provide the services and information you request. It is our goal to deliver the best possible service to you while guarding against any real or perceived infringements of your rights of privacy.
The types of information we collect during the normal course of business include:
We do not sell non-public personal information obtained from consumers or clients. Our staff realizes that providing personal information is an act of trust and takes the issue of protecting privacy seriously.
We limit access to non-public information to only those who require the information for the delivery of advisory/administrative services. Our policy to protect client information extends beyond the termination of the client agreement. Additionally:
All information provided by clients to us and information and advice furnished by us to clients is treated as confidential and is not to be disclosed to unaffiliated third parties, except as permitted by clients with written authorization, by application to facilitate the investment advisory services offered by us via an unaffiliated financial services provider, or as required by law or by any regulatory authority to which we or our associated persons are subject.
Appointment reminders, request for contact, and non-protected personally identifiable information may be sent or requested via SMS.
We maintain a variety of security measures to protect against the loss, misuse and alteration of Information under our control. Although we make good-faith efforts to maintain the security of such Information, we cannot guarantee that it will remain free from unauthorized access, use, disclosure or alteration. Further, we cannot guarantee that our security measures will prevent unauthorized persons from accessing or obtaining this information. We assume no liability to you or any other party in relation to the unauthorized access, use or alteration of any information provided to us.
If we become aware of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Site or providing Information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Site. If you believe that there has been a breach of the Site’s security, please contact us at (248) 481-8793.
We may update or amend this Privacy Policy at any time. No prior notice of any update or amendment is required, and all updates or amendments are effective upon being posted. We encourage you to periodically review this Privacy Policy to stay informed about our collection, use and disclosure of Information on the Site. Your continued use of the Site constitutes your agreement to this Privacy Policy and any updates.
If you have questions about this Privacy Policy or these SMS Terms & Conditions, you may contact us at (248) 481-8793.
