Porter, White & Company, Inc. (Broker Dealer), Porter White Investment Advisors, Inc. (Registered Investment Advisor) and affiliated companies (together “PW&Co”) are committed to preserving the privacy of clients. This notice describes how we deal with information concerning them.
(1) We collect nonpublic personal information about clients from the following sources: Information we receive from clients on applications or other forms; information about transactions with us, our affiliates, or others; and information we may receive from a credit reporting agency. This information may include (but may not be limited to):
Name and address, including email address;
Social Security or taxpayer identification number;
Account balance; and
(2) We do not disclose any non-public personal information about clients or former clients to non-affiliated parties, except as directed by clients, as necessary in order to service a client account or as otherwise permitted by law. Your information is used by us or our service providers primarily to complete transactions or account changes that you request or authorize. In the normal course of serving clients, information we collect may be shared with companies that perform various services for us, such as transfer agents or custodians. The organizations that receive client information receive only the information necessary to carry out their assigned responsibilities and are authorized to use that information only for the services required.
We may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required or permitted by law (for example, to cooperate with regulators or law enforcement authorities, such as responding to a subpoena or other legal process, or to protect accounts from fraud), or to resolve client disputes.
PW&Co will erase or destroy any information obtained from a consumer reporting agency that identifies an individual and that is not required to be kept for recordkeeping purposes.
(3) Access to clients’ non-public personal information is restricted to employees and third parties hired to perform services for us who need to access such information to provide products or services. To guard clients’ non-public personal information, we have imposed physical, electronic, and procedural safeguards. A client’s right to privacy extends to all forms of contact with us, including telephone, written correspondence, and electronic media, such as the Internet.
January 1, 2019