We have adopted this policy with recognition that protecting the privacy and security of the personal information we obtain about our customers is an important responsibility. To service you in an accurate and efficient manner, we must collect and maintain certain personal information about you. We want you to know what information we collect and how we use and safeguard that information.
Information We Collect from You
We collect certain nonpublic personal identifying information about you (such as your name, address, social security number, date of birth, etc.) from information that you provide on applications or other forms as well as communications (electronic, telephone, written or in person) with you or your authorized representatives (such as your attorney, accountant, etc.). We also collect information about your bank accounts and transactions (such as bills and invoices paid, account balances, inquiries, etc.), information to process transactions or to conduct online transactions.
Information from Third Parties
Though we do not normally collect information from third parties about our clients, there may be occasions when we have to do so, primarily from your other financial advisors. In those cases, we need to be able to rely on the correctness, accuracy and timeliness of the information provided to us by third parties.
Information We Share
We share information with third parties only in a limited way to conduct business and provide service to customers, or as required by applicable law or court order. In general, the only information that would be shared would be with your financial advisors such as financial planners, investment advisors and tax accountants. Such sharing is authorized in the Engagement Letter which you signed upon retaining our services. The details of such sharing are spelled out in the authorization page where we are given explicit permission to share, and only as specified. These permissions may be rescinded or modified by you, in writing, at any time.
We only collect medical information to the extent that you send us medical bills and invoices for payment. We only share medical information if you have asked us to coordinate medical bill payment and insurance claims processing with a specialist firm you have retained for that purpose via a separate engagement letter with that firm. You may rescind or modify the sharing of this information, in writing, at any time.
What Information We Disclose
We do not disclose the nonpublic personal information we collect about you to anyone except as permitted by law.
Protection Of Your Personal Information
It is our policy to protect your personal information by doing the following:
(a) Safeguarding any data, computer files and documents containing your personal information from any misuse by third parties;
(b) Destroying, erasing or making unreadable any data, computer files and documents containing your personal information prior to their disposal;
(c) Protecting the confidentiality of your personal information;
(d) Prohibiting the unlawful disclosure of your personal information;
(f) Restricting the access to your personal information only to our employees who need such access and only to extent that it is needed; and
(g) Maintaining other physical, electronic and procedural safeguards in compliance with applicable federal and state laws and regulations.
In the event that there is ever a breach of security regarding your personal information, we intend to comply with applicable state and federal law requirements regarding the notification and disclosure to you and to the appropriate authorities of the circumstances surrounding the breach.
“Personal information” for this section is defined as any information that you may provide to us that can be used to identify you individually, including but not limited to your name, email address, home address, telephone or fax numbers, driver’s license number, state identification card number, bank account number, credit card or debit card number, passport number, alien registration number, as well as any account number that we assign to you.
100 Technology Drive
Trumbull, Connecticut 06611
Governing Law and Jurisdiction