Untitled Page
Privacy, Security and Confidentiality Statement of Policy
Button Financial has an obligation to all of its Clients to treat their accounts
and the information submitted to open those accounts with the utmost care, both
for financial reasons and to ensure the privacy, security and confidentiality of
the information given to me. Therefore, Button Financial has in place the following
measures to ensure that privacy, security and confidentiality are not breached by
outside access or unauthorized personnel.
Organization-Collected Information
Button Financial does not obtain information regarding Clients from any sources
but the Client with whom there is a working relationship. Button Financial does
not use the services of a Credit Reporting Agency or any other outside organization.
Disclosed Information
Button Financial requests a variety of informational data from each Client in order
to determine the financial needs and concerns of that Client. This information includes
the Client's annual income, net worth, investment goals and objectives, taxes, insurance,
estate planning and any other information that is pertinent to the development of
a Financial Plan and delivery of financial consulting for each Client.
Parties with Whom the Information is Shared, Including Non-Affiliated Service Providers
Information with regard to a Client account, and the personal information about
a Client that was used to establish it, is only shared with the following parties:
- Any Federal or State Regulatory Agency in the course of their review of Button Financial
business practices or as otherwise prescribed by law or court order.
- Shareholders Service Group and Charles Schwab & Co., Inc. (Schwab) are used as custodian of Client
accounts. They only receive personal information about Clients from the account
application that Clients complete and sign. Currently Button Financial uses the
custodial services of EAInvest and also gains access to retail Schwab accounts via
their website.
- Before discussing a Client's personal information with his/her attorney, tax preparer,
insurance agent, mortgage broker, etc., the client's verbal permission is always
obtained.
Information about Former Clients
Information provided by a Client that is no longer using Button Financial services
is shared only with Federal or State Regulatory Agency or as otherwise prescribed
by law or court order.
Fair Credit Reporting Act Disclosures
Shareholders Service Group and Charles Schwab & Co., Inc. (Schwab) are the custodians of Client funds
and securities for all Button Financial investment programs and products. As custodians,
they are required to meet the requirements of the Fair Credit Reporting Act. Button
Financial's data regarding account balances etc. is provided by Shareholders Service Group or Schwab.
Policies & Procedures
Button Financial discloses the following privacy policy in each Client Agreement:
"Any information and documents provided to Button Financial about you, the Client,
your family, your financial circumstances and your financial objectives will be
kept strictly confidential, except as to Button Financial's attorneys who may need
to review the files (they must keep this information confidential) and insofar as
I may be required by law or regulation to disclose such information to federal and
state regulatory authorities, or as may be required by court order. Button Financial
does not sell or rent mailing lists and will not release your name and address to
anyone outside the firm without your permission." This information is provided to
Button Financial by the Client, via the questionnaire and/or account applications
completed by the Client.
Button Financial maintains a secure office and computer environment to insure that
Client information is not placed at unreasonable risk. Anyone who may require access
to confidential Client files (Computer Consultant, Part-time Contractor,) must first
sign a Confidentiality of Proprietary Information Statement. Only those Independent
Contractors that must have access to personal Client information have the means
to view that information.
Button Financial will provide an initial notification of its Privacy, Security and
Confidentiality Policy to every Client. Annually, a copy of the policy will be sent
to Clients along with the offer for an updated ADV.
Confidentiality of Proprietary Information at Button Financial
I,
(independent contractor) recognize
and acknowledge that as a result of my working with Button Financial, I will become
aware of confidential and proprietary information concerning the firm's services,
client development and service strategies, marketing and pricing strategies, and
information about existing and future clients, all of which are valuable and unique
assets of the firm's business. Accordingly, I agree that I shall not, whether during
or after the term of my working with the firm, disclose such information to any
person, firm, corporation, or association or any other entity for any reason.
Signature:
Printed Name:
Date:
|