Personal Information Collected
The reason the “Companies” collect information is to create and foster ongoing customer relationships. In the normal course of this process, the “Companies” obtain and retain non-public (personal) information about you which is transmitted to us either directly by you or via your broker in order to open an account. This includes your name, address, tax identification number, approximate age, investment experience and other identifiable information. In addition, the “Companies” may obtain information about you through our affiliates, credit reporting services, regulatory information providers and other similar entities. The “Companies” limit such information to such facts as are necessary to establish a relationship with you as a customer and to offer accurate and superior service in the normal course of business as it relates to your account carried at the “Companies”.
The “Companies” also obtain and retain non-public (personal) information about you resulting from transactions involving your financial investments. This includes your account balances, funding and transaction history. In addition, the “Companies” obtain and retain non-public (personal) information about you in connection with information obtained through an information-collecting device from a web server, often referred to as a “cookie”.
Use of Personal Information
The “Companies” use your personal information for three general purposes:
- First, the “Companies” use the information to approve and activate an account for you and/or to make changes or additions to information previously provided to us to open an account for you.
- Second the “Companies” may use it to give you online access to your account information and the “Companies”’ proprietary information in a secured environment.
- Third, the “Companies” use the information in the normal course of business to transmit account activity statements and related documents to you relating to activity in your account with the “Companies”.
Disclosure of Personal Information
The “Companies” take very seriously their responsibilities to keep your personal information private. The “Companies” will not disclose non-public personal information about our customers except as required and permitted by law and in the following instances:
- In processing or servicing of products or services offered by the “Companies” that have been consented to, requested or authorized by the customer.
- The “Companies” may share your personal information with affiliates and subsidiaries and/or unaffiliated third parties only as is necessary to verify the accuracy of the information you have provided, to conduct identity, background and credit history checks, to process or collect payments, to service your account, for audit purposes and/or to ensure regulatory compliance.
- The “Companies” may be required to disclose personal information by law or legal process for a variety of reasons, including protecting and defending the rights or property of the “Companies” and periodically reporting trading gains or losses as required by the Internal Revenue Service. The “Companies” may also be required to disclose personal information to the regulatory bodies whose jurisdiction they are subject to.
Except under the circumstances described above, The “Companies” will not disclose any of your personal information to unaffiliated third parties, unless specifically authorized by you in writing to do so. The confidentiality and conditions of this agreement will continue to be maintained even when you cease to do business with the “Companies”.
How the “Companies” Protect Personal Information
The “Companies” take reasonable measures to protect your personal information from unauthorized access through the use of physical security, and use and access policies for employees. The “Companies” safeguard customer information from unauthorized access by their confidentiality policies and/or limiting the number of employees permitted to access such information through personalized staff passwords, and by having in place a process for disciplinary action where appropriate.
Additionally, customer, or account activity related information is protected on the “Companies” Web sites with a variety of security measures such as change control procedures, passwords, and physical access controls. The “Companies” also employ a variety of other mechanisms to protect a user’s data from being lost, misused, or altered inappropriately. Although the “Companies” take these measures to safeguard against unauthorized use of a user’s data, the “Companies” cannot control Internet transmissions and cannot provide assurances that personal information transmitted to the “Companies” will never be compromised.
Information Sharing with Affiliates of the “Companies”
Although by law we are permitted to share information with our affiliates and subsidiaries related to our transactions and experiences with you, it is the policy of the “Companies” not to do so without your authorization, except in the limited circumstances referenced above. Accordingly, the “Companies” will not share any personal information either provided by you or obtained from third parties, unless it is necessary to do so for the purposes described above or it is required by law or regulation or unless we have your specific written authorization.
Accuracy of Personal Information
On an ongoing basis the “Companies” evaluate their efforts to protect your personal information and ensure its accuracy. Should you identify any inaccuracy in the personal information included in any communication you receive from the “Companies”, please notify Three Lakes Advisors at 203-388-2678 or the ADMIS Compliance Department immediately at 1-800-243-2649. The “Companies” will take reasonable steps to ensure it is corrected on a timely basis.