TYPES OF NONPUBLIC PERSONAL INFORMATION (“NPI”) WE COLLECT
We collect NPI about you that is either provided to us by you or obtained by us with your authorization. This can include but is not limited to your Tax ID Number, Banking Information and Financial Account Numbers and/or Balances, Sources of Income, or other Information. When you are no longer a client, we may continue to share your NPI only as described herein.
PARTIES TO WHOM WE MAY DISCLOSE INFORMATION
As a policy, SWM does not share your NPI with any non-essential vendor, third party, affiliate, or non-affiliate other than parties “as permitted by law” and that SWM may need to share NPI with to service your account(s); those include, but are not limited to, affiliates, non-affiliates, and vendors that process your transactions and maintain your account(s), custodian interactions, and to respond to court orders and legal investigations. Even in those cases, any affiliates, non-affiliates or vendors are bound by strict non-disclosure agreements or there are other legal safeguards that protect your NPI from further disclosure.
PROTECTING THE CONFIDENTIALITY OF CURRENT & FORMER CLIENT’S INFORMATION
To protect your NPI from unauthorized access and use, we use physical, electronic, and procedural safeguards that comply with federal law, including computer safeguards, secured files and a secured building. To mitigate a possible breach of NPI SWM will make every effort to use systems and storage facilities, including computer systems and back-up locations, that are deemed to be secure. SWM will also restrict access to your NPI and account information to those employees who need to know that information to provide products or services to you.
As a result of this limited sharing, all of which is “permitted by law,” there is no option to opt-out of our information sharing protocol