YOUR PRIVACY IS IMPORTANT TO US
Information We Collect
We collect and retain information about you to identify and communicate with you, to provide you with products and services that you have requested and to help us respond to your questions. We collect nonpublic personal information from the following sources:
We have procedures to ensure that your information is maintained in a commercially reasonable manner so that it is accurate, current, and complete. Keeping your information secure is one of our most important responsibilities. We restrict access to non-public personal information about you to those employees and agents who need to know the information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your non-public personal information. We also have procedures to ensure that requests to correct inaccurate or incomplete information are acted upon in a timely manner.
- Information we receive from you on applications and other forms (for example, name, address, social security number, assets, and income);
- Information about your transactions from us, our affiliates (including your credit union or its affiliates) or non-affiliated third parties such as our clearing firm, mutual fund companies, insurance companies, money managers, and/or your prior brokerage firm (in the case of an account transfer);
- Information obtained when verifying the information you provide on an application or other forms (this may be obtained from other institutions where you conduct financial transactions); and
- In some cases, we may collect information from consumer reporting agencies.
Disclosure of Personal Information to Non-Affiliated Third Parties
We do not disclose or sell personal information about you or our former customers to non-affiliated third parties, except as permitted or required by law or regulation. We may disclose all of the information we collect to companies with whom we have a financial services agreement to offer financial products and services to you, including your credit union and its affiliates. We have entered into a written agreement with your credit union to jointly offer financial services whereby the credit union agrees to comply with applicable Privacy Regulations to protect your confidential information.
Disclosure of Personal Information in Other Circumstances
We are dedicated to offering competitive high quality services to you through our relationship with your credit union. Our relationship with credit unions is structured to protect your personal information. For example, we do not release or sell customer information to telemarketing companies. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your personal information. We protect your account information by placing it on the secure portion of our website. Our servers have been enabled with Secure Sockets Layer (SSL) technology to prevent unauthorized parties from viewing your personal information. In addition, we employ GeoTrust digital certificate services to authenticate that you are connecting to our server(s). Access to your personal information is limited to those employees, registered representatives and agents who may need to know that information to provide products or services to you. They are required to maintain the confidentiality of all customer information.
Although privacy regulations generally prohibit the sharing of personal information, we may share the following information pursuant to specific exceptions:
When we share confidential customer information with a third party, these companies are contractually obligated to keep the information that we provide to them confidential and use the information only for the services required and as allowed by applicable law or regulation, and are not permitted to share or use the information for any other purpose. That is, we require such third parties to agree to safeguard personal information regarding our customers in accordance with our own privacy policies.
- Disclosures made pursuant to a written agreement that prohibits the third-party from disclosing or using the information for purposes other than those in the agreement.
- Disclosures that are necessary to effect, administer or enforce a transaction for a financial service or product that the client requests or authorizes.
- Disclosures to credit agencies.
- Disclosures permitted or required by law in order to prevent fraud, control risk, resolve complaints or as otherwise required by law.
- Your credit union, your credit union's credit union service organizations or other financial service providers that perform services on our behalf. The above disclosures are permitted under the Regulations of the Securities and Exchange Commission. There may be some states in which we do business that would prevent us from disclosing personal information in one or more of the situations described above, without a right to opt-out or a requirement to opt-in. We will respect the state requirements as they may apply to our affected customers.
If you have any questions, you may contact our Legal and Compliance Department at (858) 530-4400, or firstname.lastname@example.org.