Pine Creek Financial Group LLC Privacy Policy

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.

These laws govern our treatment of our customers’ nonpublic personal information and restrict our sharing of that information with our own affiliates as well as unaffiliated third parties. We may share information about our own experience with our customers with our affiliates or with third parties. Privacy laws require us to disclose our privacy policies and practices to our customers and allow our customers to opt out of certain sharing practices. This privacy policy adheres to the Regulations. Our clients receive a copy of this policy during the disclosure process within 3 days of application. It is also posted on our website www.ThePCFGroup.com.

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 receive from you on applications or other forms, over the telephone or in face-to-face meetings, and via the Internet. Examples of information we receive from you include your name, address, telephone number, social security number, credit history and other financial information.
  • Information about your transactions with us or others. Examples of information relating to your transactions include payment histories, account balances and account activity.
  • Information we receive from a consumer reporting agency. Examples of information from consumer reporting agencies include your credit score, credit reports and other information relating to your creditworthiness.
  • From employers and others to verify the information you have given to us. Examples of information provided by employers and others include verifications of employment, income or deposits.

Information We Disclose

  • Your personal information will only be retained for providing you with our response to your query and will not be made available to any third party except as necessary to be disclosed to any related entity for the purpose intended or as required to be disclosed under law.
  • By submitting data on our website, secured portal, or electronic transmission, the visitor is providing explicit consent to the transmission of data collected.
  • We treat data as confidential within our firm and require a strict adherence of all our employees to data protection and our confidentiality policies.
  • All visitors, however, should be aware that transmission may contain links to other sites that are not governed by this or any other privacy statement.
  • We reserve the right to amend (that is, add to, delete or change) the terms of this Privacy Statement from time to time.

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: 

  • Specific customer authorization.
  • Administrative subpoena or summons. (This method is usually used if customer authorization has not been obtained.)
  • Search warrant.
  • Judicial subpoena.
  • Formal written request (available only to government agencies that do not have the authority to issue an administrative subpoena or summons). 

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

The privacy protection provisions of the Gramm-Leach-Bliley Act require us to provide a privacy notice to each of our clients. Our practice is to provide this notice when we first meet with the person or send any information, whichever first occurs. Additionally, if a client is inquiring about financing through our website, the privacy policy is posted on the website. Two or more persons applying jointly requires only one copy of the notice, as required by law, we also provide the notice to our customers on an annual basis if they are part of our servicing portfolio.

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. 

CAN-SPAM Act

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:

  • Clearly and conspicuously label the message as an advertisement or solicitation.
  • Include clear and conspicuous opt-out instructions with reference to a functioning return e-mail address or another Internet-based mechanism for opting out of future email.
  • Include our postal address. 
  • Do not use false or misleading header (source, destination, and routing) information. 
  • Do not use deceptive subject headings.
  • Do not transmit spam after objection. (including transferring or releasing an email address after an objection)
  • Educate employees about the CAN-SPAM Act.

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. 

DISCLAIMER:
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.



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