Your Privacy is Important to us
We value you as a customer and take your personal privacy seriously. We
are committed to maintaining the confidentiality, integrity and security
of your personal information. When you provide personal information, we
believe that you should be aware of our policies to protect the confidentiality
of that information. We will inform you of our policies for collecting,
using, securing, and sharing nonpublic personal information the first time
we do business and every year that you are our customer.
Information
We May Collect
We collect and use information we believe is necessary to open your account,
to process your transactions, to advise you about our products and services,
and to provide you with customer service. We may collect and maintain several
types of information needed for these purposes include information we receive
from you on applications or other forms, and information about your transactions
with our affiliates, others, or us.
How We Use Information
About Our Customers
We think that our ability to share financial information within our company
enables us to more effectively serve our customers in several ways. By knowing
about investors' finances and goals, we are better informed to make suitable
investment recommendations. Information sharing protects individuals against
fraud by enabling us to more precisely monitor and detect where and when
fraud may occur.
Protecting The Security and Confidentiality
of Information
It is our policy to assure that the information we have about our customers
is accurate. It is our policy that information we have about our customers
is highly confidential and should only be available to persons who have
a need for the information to properly service a customer's account, act
upon a customer's request or to fulfill that person's job responsibility
within our company. We restrict access to nonpublic personal information
about you to those employees with a legitimate business need for the information.
We maintain physical, electronic, and procedural safeguards that comply
with federal standards to guard your nonpublic personal information.
Information Sharing
There are two types of information sharing--information sharing with our
affiliates and information sharing outside Rogan and Associates. We do not
sell customer information. We do not provide customer information or account
numbers to persons or organizations outside our company who are doing business
on our behalf for their own marketing purposes.
Information We May Share
We are permitted by law to share nonpublic information about you with
third parties for the following purposes:
- To complete a transaction.
- To produce a consolidated or non-consolidated account statement.
- To service your account.
- To cooperate with regulators or law enforcement authorities.
- To resolve customer disputes.
In order to perform our responsibilities as listed above, we may be required
to disclose to third parties the following kinds of nonpublic personal
information about you:
- Information we receive from you on applications and other forms, such
as your name, address, social security number, assets, net worth, income
and tax status; and
- Information about your transactions with our affiliates, others, or
us such as your account size, payment history, parties to transactions,
and trading frequency.
Categories of Third Parties To Whom We May Provide Information
Information we share about you may be disclosed to our affiliates, which
include companies we hire to provide support services, such as carrying
and executing broker/dealers, clearing firms, custodians, mutual fund
distributors, portfolio managers, insurance companies, independent auditors
and accountants. We may be required to disclose your nonpublic personal
information to regulators or law enforcement authorities.
Companies we hire to provide support services are required by us to protect,
to keep confidential and to restrict the use of your nonpublic personal
information.
We do not disclose customer account numbers to any third parties for use
in telemarketing, direct mail marketing, or other marketing through electronic
mail to the consumer.
Former Customers
We may disclose nonpublic personal information about our former customers
to the same extent as for our current customers.
Your Choice To Share Information
The law permits us to share your identifying information and information
about your transactions with nonaffiliated third parties for the purposes
described above. We do not share your information with nonaffiliated third
parties for any other reasons. Therefore, we are not providing an opt-out
provision for information shared with nonaffiliated third parties.
The law permits us to share your identifying information and information
about your transactions with our affiliated parties. Unless you tell us
not to, we may share other information with our affiliates, including information
we receive from you on applications and other forms, or information we receive
from a consumer reporting agency. If you prefer that we not share these
kinds of information with our affiliates, you may direct us not to share
this information by calling us at the following toll-free number: 1-866-779-3258.
USA PATRIOT ACT Client Verification
In response to the terrorist attacks on September 11, 2001, the US Congress
passed the USA PATRIOT Act. To help the government fight the funding of
terrorism and money laundering activities, Federal law requires all financial
institutions to obtain, verify, and record information that identifies
each person who opens an account. What this means for you: When you open
an account, we will ask for your name, address, date of birth and other
information that will allow us to identify you. We may also ask to see
your driver's license or other identifying documents. We may also screen
your name against various databases to verify your identity.
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