Protecting the privacy of your information is among our highest priorities. As a financial services firm, we collect and use nonpublic personal information (“NPI”) to provide our clients (prospective, current, or former) with a broad range of financial services as effectively and conveniently as possible. We are providing this notification to inform you of the types of NPI we collect, our privacy safeguards, and sharing practices. We handle all NPI in accordance with this policy.
WHAT IS NPI?
Nonpublic personal information (NPI) is confidential personal information about you that we obtain in connection with providing financial services to you. As a prospect or once you become a client, you provide us with certain personal and financial information. We generally collect NPI about you (e.g., name, address, tax identification number, driver’s license number, assets, income, net worth, employment, etc.) from the applications, questionnaires, or forms you complete. We collect this information to evaluate your financial goals and objectives, provide you with additional information about our products and services, and initiate the requisite financial transactions.
HOW IS YOUR NPI UTILIZED?
We utilize your NPI to facilitate certain transactions with our firm or specific transactions through authorized unaffiliated service providers such as account custodians (i.e., broker-dealers, banks, and money managers) chosen by mutual agreement, and others who need to know such information in order to provide products or services to you. We may also share your NPI with other unaffiliated service providers (e.g., insurance agents, attorneys, accountants, etc.) that you have authorized to have access to your NPI to conduct business with you and on your behalf. Disclosure of NPI to such parties is unrestricted and facilitated by your agreement and express consent, as permitted and required by law. We restrict access and sharing of your NPI to employees of our firm and only others who need to know such information as a provision of our services. In all other permissible sharing events, companies must agree to keep your information confidential and are not permitted to use or share your information for any other purpose.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
Internally, we maintain physical, electronic, and procedural safeguards to protect your NPI. Our safeguards include measures to protect your information prior to, during, and upon the termination of our financial services engagement. Moreover, we ensure that access to your NPI is limited to and only accessible by those who need to know it in order to provide our business-related services.
OTHER INFORMATION SHARING
As indicated, we may disclose your NPI to unaffiliated services providers, regulatory authorities, and law enforcement agencies. For example, we may disclose your NPI to our attorneys, accountants, auditors, or at the request of a regulatory agency in connection with the assessment of our compliance with industry standards. Carlton Wealth reserve the right to disclose or share your NPI with unaffiliated service providers as described herein and as permitted by law. In the foregoing cases, these organizations must agree to keep your NPI confidential.