A. CEG may collect nonpublic personal information about CEG’s clients and potential clients from the following sources:
• Information received from account applications, written questionnaires, interviews/conversations, information forms and other client interactions;
• Information about transactions with CEG, any affiliates of CEG, or others; and
• Information CEG obtains or receives from a consumer reporting agency.
All client information is to be maintained in CEG’s master client files and/or stored on appropriate electronic media. Information from potential clients may be filed in temporary files, but shall be subject to the same restrictions and limitations as other client files outlined below.
B. Adviser personnel are prohibited from sharing or disclosing nonpublic information regarding any client or potential client of CEG, except (i) as necessary to service client accounts including, without limitation, the settlement, billing, processing, clearing, or transferring of client transactions; or (ii) as otherwise directed by a client. Access to all client files and information, whether in paper or electronic format, is limited to Adviser personnel for the purposes of servicing client accounts.
C. Adviser personnel may not remove client files or information from CEG’s premises unless (i) it is necessary to service client accounts; and (ii) prior approval is obtained from the Chief Compliance Officer.
D. All client files are secured at the end of each business day, and exterior doors always remain locked..
E. All computers are set up so they ‘lock’ when not in use, requiring a password to gain access.
F. Traffic flow in the office is restricted, and no individuals, other than employees, are allowed free access to areas where client information is held.
G. Employees working remotely must utilize passwords to gain access to the CEG system servers.
H. CEG will provide clients with a privacy notice (the “Privacy Notice”) when the client engages CEG for advisory or other services. The Privacy Notice details the types of nonpublic client information CEG collects, the information CEG shares with third parties or with affiliates, the kinds of third parties with which CEG shares information, the policies and practices TWM has in place to protect the confidentiality and security of nonpublic client information; the procedures CEG has in place to permit clients or potential clients to opt out of information sharing arrangements with third parties (inapplicable to CEG so long as CEG only shares information with third parties for purposes of servicing client accounts), and CEG’s disposal policy.
I. CEG shall deliver an updated Privacy Notice to all of its clients annually, even if the policy has not changed since the previous year. “Delivery” may, to the extent allowed by law, mean notification of the availability of the notice on a website.
J. Privacy Notices may be included in a quarterly report, newsletter or other client mailing. A copy of CEG’s current Privacy Notice is attached hereto.
K. CEG has undertaken to protect client information in the course of its disposal as well. Employees either utilize personal desk-side shredders or place material to be shredded in a secure retention container. Here it is held until American Recycling arrives to shred materials in bulk.
This is for your information only. No action is required on your part.
What Information We Collect and From Whom We Collect It
We may collect nonpublic personal information about you from the following sources:
• Information we receive from you on applications or other forms;
• Information about your transactions with us, our affiliates or others; and
• Information we receive from non-affiliated third parties, including consumer reporting agencies.
“Nonpublic personal information” is nonpublic information about you that we obtain in connection with providing a financial service or product to you.
What Information We Disclose and To Whom We Disclose It
We do not disclose any nonpublic information about you without your express consent, except as permitted by law. This applies to current as well as former clients. We restrict access to your nonpublic personal information to those employees, affiliates and independent third parties who need to know that information in order to provide products services to you.
Our “affiliates” are companies with which we share common ownership. We do not currently have any affiliated companies.
Our Security Procedures
We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information. This includes measures to protect your information in the course of its disposal.