- We collect nonpublic personal information about our clients from many sources including the following:
- Applications or other forms (such as name, address, social security number, assets, and income).
- Clients’ transactions with us or other or your financial organizations,
- Consumer reporting agencies (such as credit worthiness and credit history).
- Our internal data security policies restrict access to nonpublic personal information to authorized employees. We maintain physical, electronic, and procedural safeguards that are designed to comply with federal standards to guard our clients’ nonpublic personal information. Employees who violate our data security policies are subject to disciplinary action, up to and including termination.
- We may disclose nonpublic personal information about our clients to our affiliates, such as banks, mortgage lenders, and securities broker-dealers, in order to provide our clients with access to product offerings and product upgrades, and in order for our affiliates to provide services to us, such as data processing and loan servicing. We may disclose to our affiliates all of the information that we collect, as described above.
- We may disclose nonpublic personal information about our clients to nonaffiliated third-parties with whom we have contracted to perform services on our behalf, such as, printing, mailing, fraud prevention, and data processing services, as well as nonaffiliated financial organizations with which we have clearing agreements. We may disclose all of the information that we collect, as described above. We may also disclose nonpublic personal information about our clients as permitted or required by law.
- We do not disclose nonpublic personal information about former clients, except as permitted or required by law.