Privacy Policy Statement
Maintaining the trust and confidence of our clients is a high priority. That is why we want you to understand how we protect your privacy and the integrity of the information we collect and use about you, and the steps that we take to safeguard that information.
Information We Collect
In the course of providing clients with our services, we obtain nonpublic personal information about you, including:
Information we receive from you verbally, on client account applications, or on other forms
Information about your assets and transactions with us, our affiliates, or other parties including additional advisors (i.e. attorney or banker)
Information we receive from credit or service bureaus or other third parties
Information We Disclose
We will not disclose nonpublic personal information regarding you or your account with us except under the following circumstances:
To your authorized registered representative
To establish or maintain an account with an unaffiliated third party or provider of services (i.e. attorney, auditor, prime broker, or custodian)
To our affiliated firm, Desmond Consulting Group, a certified public accounting firm that is 100% owned and operated by our principal, if we believe that you may be interested in the services provided; we do this in order to permit the CPA firm to determine whether to contact you about such services
To government entities or other third parties in response to subpoenas, court orders, or other legal/judicial processes as required by law
To our custodian of client assets, Fidelity Institutional Investments, or their affiliates, to the extent permitted by law
As authorized by client consent with written permission
Our Security Policy
We also restrict access to your nonpublic personal information:
Among our own personnel and only those individuals who need information to perform their jobs are authorized to have access to confidential client information
Where we are not comfortable that an unaffiliated third-party service provider (i.e. financial service companies, consultants, attorneys, or auditors) is already bound by duties of confidentiality, we will require contractual assurances that they will maintain the same level of confidentiality and integrity of any of your information they obtain; and
We maintain physical, electronic, and procedural security measures that comply with applicable state and federal regulations to safeguard confidential client information
Closed or Inactive Accounts
If you decide to close your account(s) or become an inactive client we will adhere to the privacy policies and practices as described in this notice, and as required by federal and state securities laws, and the CFP Board Code of Ethics and Professional Responsibility. After this required period of record retention, all such information will be destroyed.
Changes to this Privacy Statement
If we make any substantial changes in the way we use or disseminate confidential information we will notify you.
If you have any questions about our practices with respect to your nonpublic personal information, you may contact us at (925) 932-1994.