For purposes of this policy, the terms “Consumer”, “Client” and “Confidential Information” have the following definitions:
A. “Consumer” is not necessarily a client but may be anyone who obtains financial products or services from IWC used primarily for personal, family or household purposes. Examples of consumer relationships include: (1) a prospect with whom IWC is actively pursuing an investment relationship; or (2) a prospect who provides IWC with nonpublic information (such as net worth information or potential portfolio size) after attending a seminar or community event or listening to a radio talk show at which an employee of IWC is a featured speaker.
B. “Client” means (1) an individual with a specific and continuous relationship with IWC who obtains or has obtained a financial product or service from IWC used primarily for personal, family or household purposes; or (2) that individual’s designated representative.
C. “Confidential Information” is personally identifiable private information (information not available from public sources such as the phone book or a website) about the client or consumer, including information regarding name and address, age, social security number, assets, income, net-worth, account balance, account number, bank account information, beneficiary information and investment activity (such as purchase and redemption history).
IWC collects nonpublic information about clients and consumers. We will not share nonpublic personal information about clients or consumers with third parties not affiliated with IWC, except as noted below. Specifically, IWC may share personal information as necessary:
A. To complete transactions or account changes as directed or authorized by the client;
B. To maintain or service a client’s account;
C. With a client’s accountant and/or attorney;
D. With contracted service providers providing administrative functions for IWC;
E. If IWC is required or permitted by law or regulatory authorities with jurisdiction over the firm to do so; and,
F. Any third party with whom the client has requested us to share information.
The following notice requirements apply to IWC’s clients.
A. Initial Privacy Notices
We will deliver an initial privacy notice to a client before the client relationship is established – that is, before we begin to manage a client’s account. We may deliver the privacy notice within a reasonable period of time after the client relationship is established if the client agrees to receive the notice at a later time.
B. Annual Privacy Notices
We will deliver our privacy notice to clients on an annual basis, defined as every 12 months. We are not required to deliver annual privacy notices to former clients.
C. Revised Privacy Notices
We will not disclose nonpublic personal information about a client to a non-affiliated third party other than as described in this policy or as permitted by Regulation S-P unless:
(1) We have provided the client with a revised notice describing the new policy;
(2) We have provided the client with an “opt out” notice; and
(3) We have provided the client a reasonable opportunity to opt out of the disclosure before IWC discloses the information to the non-affiliated third party.
IWC is not required to send privacy notices or provide opt-out elections to consumers unless we intend to share the consumer’s nonpublic personal information with a non-affiliated third party.
Safeguarding of Client Records and Information
IWC will maintain administrative, technical and physical safeguards reasonably designed to ensure the security and confidentiality of client records and information. To protect this information, we:
B. Prohibit an employee from providing client information over the telephone or in response to an e-mail message unless the employee has identified the other person as the client, a fiduciary representative of the client, an authorized agent of the client or a party that needs the information to complete a transaction for the client (such as broker-dealers, custodians or administrative service providers).
C. Limit access to confidential information about clients to those employees who need to know such information.
D. Maintain appropriate security measures for our computer and information systems, including the use of passwords and firewalls.
E. Use locks and other appropriate physical security measures to safeguard client information stored in paper format. For example, employees are expected to secure client information within locked cabinets when the office is closed.
F. Dispose of client information stored in electronic or paper form in such a manner (e.g., through the use of a shredder) to reasonably ensure such information is protected from unauthorized access.
G. Engage a third party service provider only after we have entered into a contractual agreement that prohibits the service provider from disclosing or using confidential personal information except as necessary to carry out its assigned responsibilities and only for that purpose.
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