Privacy Policy

 

 
Effective 01/08/2009
 
Preserving trust is a core value. WIN-TEAM recognizes that clients expect us to protect the information they provide us and to use it responsibly. We are strongly committed to fulfilling the trust that is the foundation of our client’s expectations. For that reason we have adopted and adhere to the following policy regarding the privacy of client personal information.
 
INFORMATION THAT WE COLLECT
 
We collect nonpublic personal financial information about clients from some or all of the following sources:
 
  • Information we receive from clients on new account forms, fact finding questionnaires and product application
  • Client transactions with us, our affiliates, and those product sponsors with whom we have selling agreements or other arrangements for the provision of services to clients
  •  Consumer reporting agencies and unaffiliated product sponsors with whom we have selling relationships and whose products our clients own
 
INFORMATION THAT WE DISCLOSE
 
We will not share nonpublic personal information concerning our clients or former clients for marketing purposes, except as permitted by law, as described below. We will not share nonpublic personal information concerning our current or former clients with affiliated or unaffiliated third parties, except as permitted by law. To the extent permitted by law, we may disclose to either affiliated or unaffiliated third parties, any of the nonpublic personal information that we collect, as identified above. Generally, we disclose client nonpublic personal information to affiliates and unaffiliated third parties that provide services to us in order that we may more effectively and efficiently service their account. We also may disclose nonpublic personal information to affiliated or unaffiliated third parties with whom we have contractual relationships that allow us to provide the products or services that our clients have requested through us. Examples of third parties with whom we may share nonpublic personal information include:
 
  • Mutual fund companies, insurance companies and other product sponsors to effect purchases and sales and allow for the servicing of client accounts
  • The broker/dealer through whom we execute equity and fixed income security transactions
  • Clearing agencies through whom we clear and settle securities transactions
  • Third party investment advisory firms with whom we have relationships for the management of client advisory accounts
  • Banks and other financial institutions with whom we have arrangements for the marketing and sale of our products and services
  • Companies that provide services to us to assist with the maintenance of required books and records or to facilitate mailings on our behalf
  • When client nonpublic personal information is shared with third parties for the purposes noted above, we ensure that there are contractual restrictions on their use and disclosure of that information
 
STEPS WE TAKE TO PROTECT CLIENT INFORMATION
 

We have security practices and procedures in place to prevent unauthorized use or access to client nonpublic personal information. Internally, client information is only available to those employees requiring access to process or service transactions with us, and those fulfilling compliance, legal or audit functions on our client’s behalf. Our computer systems utilize password protection to prevent access by unauthorized personnel, and we employ other physical, electronic and procedural safeguards to ensure the protection of client information in accordance with state and federal privacy regulations.

All clients of WIN-TEAM will be notified via USPS of any material changes to our Privacy Policy.