In November of 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA). The GLBA requires certain financial institutions, such as investment advisor firms, to protect the privacy of customer information. In situations where a financial institution does disclose customer information to non-affiliated third parties, other than permitted or required by law, customers must be given the opportunity to opt-out or prevent such disclosure. Payne Capital Management (hereinafter “PCM”, “our” or “we”) does not share or disclose customer information to nonaffiliated third parties except as permitted or required by law.
Commitment to Your Private Information. PCM is committed to safeguarding the confidential information of its clients. PCM holds all personal information provided by clients in the strictest confidence and it is the objective of the firm to protect the privacy of all clients. Except as permitted or required by law, PCM does not share confidential information about clients with nonaffiliated parties. It is the policy of PCM to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services in furtherance of the client’s engagement of PCM. PCM permits only authorized employees and affiliates who have signed a copy of PCM’s Privacy Policy to have access to client information. Employees violating PCM’s Privacy Policy will be subject to PCM’s disciplinary process. If there are any changes to this policy, we will provide clients with written notice and clients will be provided an opportunity to direct PCM as to whether such disclosure is permissible.
Why We Collect and How We Use Information. To conduct regular business, PCM may collect personal information from sources such as:
- Information reported by the client on applications or other forms the client provides to the firm
- Information about the client’s transactions implemented by the firm or others Information developed as part of financial plans, analyses or investment advisory services
To administer, manage, service, and provide related services for client accounts, it is necessary for PCM to provide access to customer information within the firm and to nonaffiliated companies, with whom we have entered into agreements.
The disclosure of information contained in any document completed by the client for processing and/or transmittal by PCM to facilitate the commencement/continuation/termination of a business relationship between the client and/or between PCM and a nonaffiliated third pa1ty service provider (i.e., broker-dealer, investment adviser, account custodian, record keeper, insurance company, etc.), including, but not limited to, the information contained in any document completed and/or executed by the client in furtherance of the client’s engagement of PCM (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding non-affiliated third-party service provider.
Sharing Information with Other Companies Permitted Under Law. PCM may disclose the client’s information: (1) to individuals and/or entities not affiliated with PCM, including, but not limited to the client’s other professional advisors and/or certain service providers that may be recommended or engaged by PCM in furtherance of the client’s engagement of PCM (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, record keeper, proxy management service provider, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. Since PCM, Inc. shares nonpublic information solely to service client accounts, the firm does not disclose any nonpublic personal information about the firm’s customers or former customers to anyone, except as permitted by law. In the event that the firm has a change to its customer privacy policy that would allow it to disclose non-public information not covered under applicable law, the firm will allow its clients the opportunity to opt-out of such disclosure.
Children. Our Site is not directed to children under the age of 18 years. By using our Site, you represent and warrant that you are at least 18 years old.
We respect the privacy of your children and do not knowingly collect or retain personally identifiable information from children under the age of 18 through this website. However, we may process personal data, on a child’s behalf, with permission from the parent or guardian. To the extent we have unintentionally collected any Personal Data on our Site from a person under the age of 18 years old, you may request and obtain removal of this Personal Data. To make such a request, please send an email with a detailed description of the specific content or information to info@paynecm.com
Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
PCM maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information. Through this policy and its underlying procedures, PCM attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.
Former Customers. Even if we cease to provide you with financial products or services, our Privacy Policy will continue to apply to you and we will continue to treat your nonpublic information with strict confidentiality.
Changes to this Policy. PCM will provide each client with initial notice of the firm’s current policy when the client relationship is established. PCM shall also provide each client with a new notice of the firm’s current Privacy Notice at least annually. If at any time, PCM adopts material changes to its privacy practices, the firm shall provide each client with a revised notice reflecting the new privacy practices.
Contact Us:
Should you have any questions regarding the above, please contact Ryan Payne, Chief Compliance Officer.
