Client financial information is never sold or made available to third parties (exceptions):
- Third parties may be used by Advisor to assist in the management or maintenance of client accounts;
- Client information may be released to client’s third party representatives at client’s direction;
- Client information may be released in accordance with applicable laws and regulations.
Collection of Information
In connection with providing clients with investment management services, we may obtain information about them from the following sources:
- Client contracts and other information that clients provide to us, whether in writing, in person, by telephone, electronically or by any other means. This information may include a client’s name, address, phone number, email address, social security number, employment information, income, investment experience, and credit references;
- Transactions on a client’s behalf. This information may include the client’s account balances, positions, investment interests and history; and
- Public sources.
Unaffiliated Third Parties
We only disclose non-public client information to unaffiliated third parties without prior client consent when we believe it necessary for the conduct of our business or as required or permitted by law, such as:
- If you request or authorize the disclosure of the information;
- To provide client account services or account maintenance;
- To respond to a subpoena or court order, judicial process, law enforcement or regulatory authorities;
- To perform services for the firm or on its behalf to develop or maintain proprietary trading or other software;
- To help prevent fraud;
- With rating agencies, persons assessing compliance with industry standards, or to the attorneys, accountants and auditors of the firm;
- To comply with federal, state or local laws, rules and other applicable legal requirements
We do not make any disclosure of client nonpublic personal information to other companies who may want to sell their products or services to you. We do not sell client lists or data.
Opt Out Provision
If, at any time in the future, it is necessary to disclose any client personal information in a way that is inconsistent with this policy, OC will give its clients advance notice of the proposed disclosure so that they will have the opportunity to either opt-in or opt-out of such disclosure, as required by applicable law.
Clients are advised that the Firm believes that sharing client private information under the circumstances noted above is either mandated by law or necessary for the Firm to conduct its business and to best service client accounts. Clients desiring to opt out of any third party disclosures should contact us immediately. Opting out may require termination our advisory contract.
Accuracy & Security
We take steps to safeguard client information. We restrict access to the personal and account information of our clients to our employees and agents for business purposes only. We maintain physical, electronic and procedural safeguards to guard your personal information.
Additionally, we have internal controls to keep client information as accurate and complete as we can. If you believe that any information about you is inaccurate, please let us know.