PRIVACY OF CLIENT INFORMATION
It is Investor Solutions’ policy to protect and safeguard the privacy and security of the personal information Investor Solutions obtains about its clients.
The Chief Compliance Officer is responsible for protecting and safeguarding the privacy and security of customer information.
Information Investor Solutions Collects
Investor Solutions collects certain nonpublic personal identifying information about its customers (such as their name, address, social security number, etc.) from information that the customers provide on applications or other forms as well as communications (electronic, telephone, written or in person) with them or their authorized representatives (such as their attorney, accountant, etc.). Investor Solutions also collects information about their brokerage accounts and transactions (such as purchases, sales, account balances, inquiries, etc.).
Information Investor Solutions Discloses
Investor Solutions does not disclose the nonpublic personal information it collects about its customers to anyone except: (i) in furtherance of its business relationship with them and then only to those persons necessary to effect the transactions and provide the services that they authorize (such as broker-dealers, custodians, independent managers, etc.); (ii) to persons assessing its compliance with industry standards (e.g., professional licensing authorities, compliance consultants, etc.); (iii) its attorneys, accountants, and auditors; or (iv) as otherwise provided by law.
Security of Information
Investor Solutions restricts access to customers’ nonpublic personal information to those persons who need to know that information to service the customer’s account. Investor Solutions maintains physical, electronic and procedural safeguards that comply with applicable federal or state standards. In furtherance of such safeguards, Investor Solutions has adopted a Data Security Policy.