Client Information Privacy Principles
Like most industries today, the
financial services industry is rapidly being shaped by technology, which
is literally changing the way we do business. To be successful in this
environment, we must continue to insure that our clients are confident
that we will manage their financial affairs expertly and confidentially.
Legacy Family Office, LLC (hereafter
"Legacy”) collects personal, private information from its clients in
order to determine the client’s specific investment goals and
objectives, which will assist in determining how to adequately service
the client account based on the services provided by Legacy, as
disclosed in Legacy’s Form ADV Part II.
The safeguarding of client information
is an issue we take seriously, and we want to assure all of our clients
that whenever information is collected and used, it is done so with
discretion. To affirm our continuing commitment to the proper use of
client information, we have set forth the following Privacy Principles,
which are designed to guide us in serving the privacy needs of our
clients.
Recognition of a Client’s Expectation of Privacy
At Legacy, we believe the
confidentiality and protection of client information is one of our
fundamental responsibilities. Moreover, while information is critical to
providing quality service, we recognize that one of our most important
assets is our clients’ trust. Thus, the safekeeping of client
information is a priority for Legacy.
Use, Collection, and Retention of Client Information
Legacy limits the use, collection, and
retention of client information to what we believe is necessary or
useful to conduct our business, provide quality service, and offer
products, services, and other opportunities that may be of interest to
our clients. Information collected may include, but is not limited to
name, address, telephone number, tax identification number, date of
birth, employment status, annual income, and net worth.
Maintenance of Accurate Information
Legacy recognizes that it must maintain
accurate client records. The above referenced information is collected
at the inception of your relationship with Legacy. Therefore, Legacy
will contact you periodically to review your overall account holdings,
and to ensure that personal/confidential information contained in your
file is accurate. Legacy also request that you review any information
provided to you related to your advisory account, and notify Legacy
promptly on the discovery of erroneous information. Legacy will respond
to a comment/request to correct inaccurate information immediately.
Limiting Employee Access to Information
Legacy’s employee access to personally
identifiable client information is limited to those employees that have a
business reason to know such information. Employees are educated on the
importance of maintaining the confidentiality of client information and
on these Privacy Principles. Because of the importance of these issues,
all Legacy employees are responsible for maintaining the
confidentiality of client information and employees who violate these
Privacy Principles will be subject to disciplinary measures.
Protection of Information via Established Security Procedures
Legacy recognizes that a fundamental
element of maintaining effective client privacy procedures is to provide
reasonable protection against the unauthorized access to client
information. Therefore, Legacy has established appropriate security
standards and procedures to guard against any unauthorized access to
client information.
Restrictions on the Disclosure of Client Information
When it comes to sharing client
information with unaffiliated companies, Legacy places strict limits on
who receives specific information about client accounts and other
personally identifiable data. Legacy may share information with such
companies if they provide a product or service that may benefit our
clients. Whenever we do this, we carefully review the company and the
product or service to make sure that it provides value to our clients.
We share the minimum amount of
information necessary for that company to offer its product or service.
We may also share information with unaffiliated companies that assist us
in providing our products and services to our clients; in the normal
course of our business (for example, with consumer reporting agencies
and government agencies); when legally required or permitted in
connection with fraud investigations and litigation; in connection with
acquisitions and sales; and at the request or with the permission of a
client.
1. Maintaining Client Privacy in
Business Relationships with Third Parties: If we provide personally
identifiable client information to a third party with which we have a
business relationship, we will insist that the third party keep such
information confidential, consistent with the conduct of our business
relationship.
2. Disclosure of Privacy Principles to
Clients: Legacy recognizes and respects the privacy expectations of our
clients. We want our clients to understand our commitment to privacy in
our use of client information. Because of our commitment, we have
developed these Privacy Principles, which are made readily available to
our clients. Clients who have questions about these Privacy Principles
or have a question about the privacy of their client information should
call Tammy Surratt at (239) 261-9612.
These Privacy Principles apply to
individuals, and we reserve the right to change these Privacy
Principles, and any of the policies or procedures described above, at
any time. Under such circumstances, we will provide you with an updated
set of our policies, and will provide adequate time for you to opt out
of any information sharing arrangement. These Privacy Principles are for
general guidance and do not constitute a contract or create legal
rights and do not modify or amend any agreements we have with our
clients.