Protecting our clients’ privacy is of paramount importance to PMSource LLC (“PMSource”). It is PMSource policy that no client information obtained by PMSource is sold or made available to third parties except that:
• Third parties may be used by PMSource to assist in the management or maintenance of client accounts (such as Custodian)
• Client information may be released in accordance with applicable laws and regulations.
We will not share nonpublic personal information about our clients with nonaffiliated third parties without prior client consent, except for specific purposes described below. This notice explains our collection, use and safeguarding of client information.
How PMSource Gathers Information
In connection with providing clients with investment management services, we may obtain information about them from the following sources:
- Client agreements 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;
Sharing Information with Nonaffiliated Third Parties
We only disclose non-public client information to nonaffiliated 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:
- To provide client account services or account maintenance;
- To respond to a subpoena or court order, judicial process, law enforcement or regulatory authorities;
- In connection with a proposed or actual sale, merger, or transfer of all or a portion of our business or an operating unit;
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. For example, we do not sell client lists and we will not sell client names to catalogue companies.
Opt Out Provision
If, at any time in the future, it is necessary to disclose any of client personal information in a way that is inconsistent with this policy, we will give our clients advance notice of the proposed disclosure so that they will have the opportunity to opt out of such disclosure.
To Whom This Policy Applies
Our Security Practices and Information Accuracy
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 of your information is inaccurate, please let us know.