NOTICE OF PRIVACY POLICY OF CAPTEX Strategic Management, LLC
Introduction
Title V of the Gramm-Leach-Bliley Act (the “GLB Act”) generally prohibits any company defined as a “financial institution”, directly or through any affiliates, from sharing your non-public personal information (“Personal Information”) with any nonaffiliated third party, unless the institution provides you with a notice of its privacy policies and practices, such as the type of information it collects about you and the categories of persons or entities to whom it may be disclosed. This Privacy Policy Notice provides you with the privacy policies and practices of CAPTEX Strategic Management, LLC (“CAPTEX”).
How Personal Information is Collected
In the course of our engagement for you, CAPTEX may collect and keep information that is necessary for CAPTEX to provide services requested by you and to administer your business with CAPTEX. During our engagement, CAPTEX may collect Personal Information about you from various sources, including: (1) from you, when you provide us with documents and other information and make available your files and other documents as part of our engagement; and (2) from your other advisors, vendors, business associates and other contacts as necessary to evaluate your financial needs and objectives and effectuate your financial goals as part of our engagement.
Type of Personal Information Collected
The Personal Information we may collect from you includes such information as name, address, social security number, federal employer identification number (“FEIN”), assets, income, net worth, bank account information, copies of financial documents and other information deemed necessary to evaluate your financial needs and objectives.
Use of Personal Information
CAPTEX may share your Personal Information with non-affiliated firms or individuals, such as your attorney, accountant or other advisor, to provide services to you or for your benefit. In the normal course of our business, CAPTEX may also disclose information about you to an attorney, accountant, bookkeeper, technician, or other advisor who has been engaged by us for your benefit to perform functions such as legal services, accounting services, record keeping, and computer related services. The services may include work needed to develop, implement or administer a plan, or execute a transaction that you request or authorize as part of our engagement.
CAPTEX may also disclose your Personal Information: (1) when you direct us or give us permission to disclose certain information; (2) as permitted by law to comply with legal or regulatory requirements; (3) when CAPTEX is required by law to disclose information; or (4) when otherwise permitted by applicable privacy laws.
CAPTEX will not provide your Personal Information to mailing list vendors or solicitors for any purpose. CAPTEX will not disclose your Personal Information to anyone for any purpose except as permitted by law and as necessary to provide services to perform the engagement.
Protection of Personal Information
CAPTEX maintains physical and procedural safeguards to protect your confidential Personal Information, whether written, spoken or electronic. CAPTEX will update its systems from time to time for the purpose of protecting confidential Personal Information. CAPTEX restricts access to your Personal Information to only those individuals who need the information to provide products or services to you or for other legitimate business purposes. These individuals are educated on the importance of maintaining the confidentiality and security of Personal Information and are required to follow procedures designed to protect confidential information.
Method of Disposal of Personal Information
After we no longer need or are required to keep any of your Personal Information, CAPTEX will store or destroy it in a manner that complies with applicable law and is designed to prevent unauthorized persons from accessing it. CAPTEX’s disposal methods may include shredding, destruction or obliteration of paper documents and erasing or destruction of electronic files.
Disclosure of This Privacy Policy
CAPTEX recognizes and respects the privacy concerns of its potential, current and former clients. CAPTEX is committed to safeguarding Personal Information. As a member of the financial services industry, CAPTEX is sending this Notice of Privacy Policy to you for informational purposes and will update and distribute it as required by law. It is also available upon request. CAPTEX reserves the right to change this Privacy Policy Notice from time to time consistent with applicable law.