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As
part of Watts Gwilliam & Company’s commitment to client trust, the
confidentiality of personal information is paramount. We maintain high
standards to protect personal information. We will remain vigilant in
protecting that information and in using it in a fair and lawful manner. This
Pledge explains our privacy commitment. It describes the personal
information that we collect and hold, and describes how we use, share
and secure it. Covered by the pledge is the personal information of
current and former Watts Gwilliam & Company clients, as well as
prospective clients who offer personal information to Watts Gwilliam
& Company as part of a potential client engagement.
In
this pledge, “personal information” refers to any information
relating to an identified individual, or any “nonpublic personal
information[i]”. What
information do we collect and how do we collect it? Based
on our relationship with you, we collect personal information from and
about you that is adequate, relevant, and appropriate under the
circumstances. This information is collected from different sources,
including, but not limited to, applications, forms, communications and
other interactions. This information may include your name, address,
e-mail address, telephone number, social security number or other
identification number, income, financial goals, interests, sources of
funds, and investment objectives. How
do we use personal information? We
use personal information to operate our business in a prudent and
efficient manner. This may include, depending on the nature of your
relationship with us, using it to evaluate financial needs; deliver
integrated financial services; process and service transactions; respond
to inquiries and requests; fulfill our obligations to you; work with
your other financial, legal, insurance, and tax advisors; verify income,
asset and obligation information; resolve disputes; prevent fraud; and
perform risk control. Additionally, we may use your personal information
to verify your identity, including, where applicable, verification in
accordance with the USA Patriot Act. What
personal information do we share externally with nonaffiliated third
parties and why do we share it? Watts
Gwilliam & Company does not rent or sell personal information. In
connection with the uses described above, we may, depending on the
nature of your relationship with us, transfer some or all of your
personal information to nonaffiliated third parties. These nonaffiliated
third parties may be financial service providers (such as securities
broker-dealers, banks or insurance companies) or others (such as
professional services organizations, regulators, professional
associations or other service providers).
Among other things, these nonaffiliated third parties (a) help us
carry out and finalize transactions; (b) mail account statements and
other information for us; (c) provide us with consulting, accounting,
legal and other services; and (d) help us develop, prepare and maintain
our services and systems. Information may be provided to professional
organizations, regulators, or others, to explain advice given to
clients. How
do we protect client confidentiality and security of information? We
educate our members and employees to treat personal information with
care, and work to limit access to this information to individuals who
need it for purposes stated in this pledge. We maintain and monitor our
physical, electronic and procedural safeguards, updating them as needed
so that we may protect personal information. We take such technical and
organizational security measures, as we deem appropriate, to keep
personal information confidential and secure against authorized or
unlawful processing, and to prevent loss, destruction or damage. We endeavor to keep our information current and complete. Information is kept only for so long as is necessary for business purposes or to meet legal and regulatory requirements. If, at any time, you become aware of any discrepancies in your personal information, please notify us and we will make the necessary corrections.
[i]
As defined under the U.S. Gramm-Leach-Bliley Act.
This generally includes, but is not limited to, nonpublic
information that you provide to us or that we obtain about you in
connection with the client relationship. |
