The trust and confidence of our customers is important to Congress Wealth Management LLC (“CWM”). For this reason we are careful in the way we collect and handle non-public, personal information about our clients (“Client Information”). This Privacy Notice describes our policies and practices regarding Client Information and how it is obtained, disseminated, and protected.
CWM is committed to safeguarding the use of personal information of our clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described below.
CWM does not collect personal Client Information through this website; however, CWM may collect information from you on application forms, agreements, profile or investment policy statements, and other documents received or processed in relation to services we provide. We also may collect information from other sources.
Information We Collect
We may collect Client Information from the following sources:
- Information we receive on contracts or other forms, such as name, address, date of birth, and social security number
- Information relating to transactions with us, our affiliates and others, such as the purchase and sale of securities and account balances
- Information we receive from third parties, such as custodians, brokers and financial services firms, as required or permitted by law
Information We Disclose
We disclose Client Information about our present or former clients to third parties only to the extent required or permitted by law. Such sharing of Client Information is applied to:
- Everyday business purposes such as processing transactions, maintaining and or servicing your account
- Cooperating with regulatory authorities, responding to court orders and legal investigations
- Taking reasonable and necessary steps to prevent fraud, unauthorized transactions, etc.
The information we disclose is limited, and essential to servicing your account, protecting your privacy and meeting obligations under state and federal law. We do not disclose Client Information requiring a notice to you for limiting such disclosure, otherwise known as “opting-out”. However, should we wish to disclose additional Client Information of yours, we will only do so with your written permission as discussed below.
Opt-In Process for Sharing Additional Client Information
Our current business practices require us to obtain from you affirmative written permission (“Opting-In”), before we disclose any Client Information outside of what is discussed above in the “Information We Disclose” section of this notice. In the event we wish to share such additional Client Information, we will provide you an Opt-In form describing the additional Client Information we seek to share, with whom we wish to share it with and for what purpose. Until such form is received by us from you, indicating your permission, such additional Client Information about you will not be shared.
- We maintain an Information Protection and Cybersecurity Program and provide awareness and train our employees
- We restrict access to Client Information to employees and service providers who are involved in providing products and services to our clients
- Employees with access to Client Information may not use or disclose such information, except for Congress Wealth Management business use
- We maintain physical, electronic, and procedural safeguards in order to protect Client Information
- When there is a need to dispose of confidential Client Information, we require our employees to shred, not discard the information
CWM often communicates with its clients and prospective clients through electronic mail (“email”) and other electronic means. Your privacy and security are very important to us. CWM makes every effort to ensure that email communications do not contain sensitive information. We remind our clients and others not to send CWM private information over email. If you have sensitive data to deliver, we can provide secure means for such delivery.
Please note: CWM does not accept trading or money movement instructions via email.
As a registered investment advisor, CWM emails may be subject to inspection by the Chief Compliance Officer (“CCO”) of CWM or its regulators.
If you have received an email from CWM in error, we ask that you contact the sender and destroy the email and its contents.
If you have any questions regarding our email policies, please contact us via email at: firstname.lastname@example.org.
CWM may utilize third-party websites, including social media websites, blogs and other interactive content. CWM considers all interactions with clients, prospective clients and the general public on these sites to be advertisements under the securities regulations. As such, CWM generally retains copies of information that CWM or third-parties may contribute to such sites. This information is subject to review and inspection by the CCO of CWM or the securities regulators.
Information provided on these sites is for informational and/or educational purposes only and is not, in any way, to be considered investment advice nor a recommendation of any investment product. Advice may only be provided by CWM’s advisory persons after entering into an advisory agreement and once CWM is provided with all requested background and account information.
If you have any questions regarding these policies, please contact us via email at: email@example.com.