- Types of Information We Collect
The firm collects nonpublic personal information from the following sources:
- Information You Provide: Our client engagements routinely require us to obtain private information about you so that we can proceed with the various services we perform for our clients as part of the professional relationship.
- Other Sources: Depending upon the particular service a client has engaged the firm to complete, we may request nonpublic information concerning the matter at hand. However, this information is never obtained without our client’s authorization for the type of information and the source(s) from which it may be obtained.
- Examples of sources from which we collect information include:
- interviews and phone calls with you
- letters or e-mails from you
- address and phone contact data obtained from third-party skip-trace providers
- public records available from government court and defense department sources
- Parties to Whom We Disclose Information
Our firm policy is never to disclose nonpublic information. Nonpublic personal information is defined in the regulations as any publicly available information that we acquire by using information you have provided us in connection with any professional services we perform, which is not public information. In a generic sense, any information provided to us that involves financial product or service is likely considered nonpublic personal information and receives protection from disclosure. As a general rule, we do not disclose personal information, however, to the extent permitted by law certain nonpublic information about you may be disclosed in the following situations:
- Employees of the firm: Employees who need such information to conclude a transaction for which you or our client has engaged the firm.
- To comply with a validly issued and enforceable subpoena or summons.
- In the course of a review of our firm’s practices under the authorization of a state or national licensing board, or as necessary to properly respond to an inquiry or complaint from such a licensing board or organization.
- Service Providers: As with any business, we have our own accounting, insurance and other service firms that we may need to provide information that the regulations consider nonpublic personal information. An example might be computer consultants that must have access to certain client records so as to be able to increase the efficiency of our computer processing systems. We have always insisted that any such information that needed to be disclosed for a business purpose be considered confidential and not used for any purpose other than the specific business need. That well-understood business policy of confidentiality will be reinforced as needed by contractual agreements between such service providers to the firm, referencing the Federal Trade Commission (FTC) regulations.
- In conjunction with a prospective purchase, sale, or merger of all or part of our practice, provided that we take appropriate precautions (for example, through a written confidentiality agreement) so the prospective purchaser or merger partner does not disclose information obtained in the course of the review.
- As a part of any actual or threatened legal proceedings or alternative dispute resolution proceedings either initiated by or against us, provided we disclose only the information necessary to file, pursue, or defend against the lawsuit and take reasonable precautions to ensure that the information disclosed does not become a matter of public record.
- To provide information to affiliates of the firm and nonaffiliated third parties who perform services or functions for us in conjunction with our services to you, but only if we have a contractual agreement with the other party which prohibits them from disclosing or using the information other than for the purposes for which it was disclosed. (Examples of such disclosures include using an outside service bureau to provide contact and location information.)
- Others: Other than as state above, we do not disclose nonpublic personal information, or any other information, to any outside party without specific client authorization.
- Confidentiality and Security of Nonpublic Personal Information
We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard nonpublic personal information and any other information, to ensure our clients that their privacy is a major part of the firm’s commitment to provide the finest service possible.
Except as otherwise described in this notice, we restrict access to nonpublic personal information about you to employees of our firm and other parties who must use that information to provide services to you. Their right to further disclose and use the information is limited by the policies of our firm, applicable law, and nondisclosure agreements where appropriate. We also maintain physical, electronic, and procedural safeguards in compliance with applicable laws and regulations to guard your personal information from unauthorized access, alteration, or premature destruction.
- Opt Out Provision
The Federal Trade Commission regulations provide that this notice must include a provision for you to request that the firm not release your nonpublic personal information. While such a request is unnecessary, because the firm does not disclose your nonpublic personal information in a manner that would allow you to opt out, in the interests of satisfying regulations, we include this Opt Out Provision.
Please call us at (855-526-9324) if you have any questions, because your privacy, our professional standard, and the ability to provide you with quality professional services are very important to us.
ver 2 effective 1/9/2019