Customer service is very important to us. As we continue to improve and expand our services, we recognize our customers' need and desire to preserve their privacy and confidentiality. Safeguarding our customers' privacy is also very important to us. We have adopted standards that help maintain and preserve the confidentiality of customers' nonpublic personal information. The following Statement affirms our continued efforts to safeguard customer information.
Our objective is to ensure that our customers’ non-public information adheres to the laws established by all States and the Federal Government. We comply with disclosure requirements and information-sharing restrictions of the Gramm-Leach-Bliley Act and its Regulation P, as well as the Fair Credit Reporting Act and its Regulation V.
Information We Collect
We gather nonpublic personal information about our customers as may be necessary to conduct business with our customers. We collect nonpublic personal information about you from the following sources:
Information We Disclose
Privacy Laws and Regulations
Several federal laws directly affect the privacy of our customers’ information. For example, the Right to Financial Privacy Act (RFPA) restricts the federal government’s ability to obtain the information we keep about our customers. Other laws, described below and in other chapters of our Compliance Policy and Procedure manual, limit the information we may collect or require us to keep certain data about our customers.
The Right to Financial Privacy Act
The RFPA requires the federal government to follow specified procedures when it requests information about our customers. In general, the federal government may obtain customer records in one of five ways:
Certain influential government agencies, such as the Internal Revenue Service and the Drug Enforcement Agency, have their own special means of obtaining customer information. Agencies pursuing their supervisory functions, such as the CFPB preparing to do an examination, are not required to comply with the RFPA because the RFPA focuses on requests for information about specific customers.
Government requests for information initially should be handled like other requests for customer information. You should immediately contact the Chief Operations Officer for instructions. As the RFPA requires, we will then require the government representative to provide a certificate of compliance with the RFPA before we provide any information about a specific customer.
The Gramm-Leach-Bliley Act
We may disclose information to affiliates or nonaffiliated third parties. If a consumer notifies us that he or she wishes to opt out of disclosure of information to members of our corporate family or other third parties, they must contact the toll-free number included in our policy to complete this process.
The Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (the CAN-SPAM Act), effective January 1, 2004, imposed requirements on the use of unsolicited commercial electronic mail messages ("spam"). In enacting the Act, Congress made the following determinations of public policy: (1) there is a substantial government interest in the regulation of commercial electronic mail on a nationwide basis; (2) senders of commercial electronic mail should not mislead recipients as to the source or content of such mail; and (3) recipients of commercial electronic mail have a right to decline to receive additional commercial electronic mail from the same source. The term "commercial electronic mail message" means any electronic mail message the primary purpose of which is the commercial advertisement or promotion of a commercial product or service (including content on an Internet Web site operated for a commercial purpose).
In compliance with the CAN-SPAM Act, if we originate spam we:
Maintenance of Accurate Information
We will attempt to keep customer files complete, up-to-date, and accurate in accordance with reasonable commercial standards.
Limiting Employee Access to Information
We limit employee access to personally identifiable information to those employees with a business reason for knowing the information. We regularly conduct training sessions and otherwise educate our staff about confidentiality and customer privacy. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. We will take appropriate disciplinary measures to enforce our employees’ privacy responsibilities.
Protection of Information
We are committed to the security of your financial and personal information. Our operational and data processing systems are in a secure environment that protects your account information from being accessed by third parties. We maintain and grant access to customer information only in accordance with our internal security standards.
This manual is the property of Pine Creek Financial Group LLC and is intended for audit or due diligence purposes. Please be advised that any disclosure, copying, distribution or other use of this information without the permission of Pine Creek Financial Group LLC is strictly prohibited.