At Convergent Wealth Advisors (“Convergent”) we recognize the importance of maintaining the utmost security and confidentiality of our customer’s information. In addition to internal policies and procedures designed to safeguard customer information, we prohibit those we do business with from any reuse of that information for purposes other than those intended by Convergent Wealth Advisors.
Accordingly, at Convergent we have adopted the following:
CUSTOMER INFORMATION SECURITY AND CONFIDENTIALITY
We take a number of steps to ensure that customer information is adequately safeguarded. These steps include the following: 1) implementing a number of physical and electronic security features to prevent unauthorized access; 2) limiting employee access to customer information; and 3) conducting periodic reviews of our computer systems, including security features. Additionally, our employees are required to acknowledge their responsibility to maintain the confidentiality of customer information.
HOW WE COLLECT CUSTOMER INFORMATION
We collect customer information about you that: 1) we receive on applications to us for our products and services; 2) we receive from processing your accounts with us and the transactions in those accounts, as well as providing services to you; and 3) we receive in response to requests made to third parties about you or to confirm information that you have provided to us.
HOW WE DISCLOSE CUSTOMER INFORMATION
We may disclose some or all of the customer information we collect about you under the following circumstances: 1) to verify or complete a transaction; 2) to verify the existence and condition of your account for a third party, such as another financial institution; 3) to a third party who performs functions on behalf of Convergent (i.e., a custodian, other broker-dealer, consultant, auditor, attorneys, etc.); 4) to comply with laws, regulations, or a court or government order or request, such as in response to a subpoena or a request by an SEC/NASD examiner; 5) to inform you of our other products or services; 6) if you or any authorized person on the account gives us oral or written permission to do so; or (7) to verify the accuracy of information that you have provided to us.
YOUR RIGHTS IF WE DID DISCLOSE YOUR CUSTOMER INFORMATION TO OTHERS
If our policies were to change and we sought to disclose your personal information to others, we could not do this without your permission. Under those circumstances, you would have the right to “opt-out” of our disclosing that information. In other words, you would be able to tell us that we could not disclose the information to any other person or entity. Should our policies change, we would provide you with detailed information prior to implementing any potential change and request your approval. At that time, we would also provide you with information on how you would be able to opt-out of us disclosing information about you.
While we do not share information about our individual clients with nonaffiliated third parties for marketing purposes, we do from time to time, as appropriate, share select information on a confidential basis with authorized colleagues within our family of companies in order to offer you financial products and services that can enhance the value you receive from your relationship with Convergent. If you are a current City National client and wish to opt-out, you can do so by emailing us at Compliance@ConvergentWealth.com.
CUSTOMER INFORMATION ABOUT FORMER CUSTOMERS
We apply the same privacy policies and practice to our former customers that we do to our existing customers. Collected customer information is retained in accordance with Federal law.
CUSTOMER INFORMATION – ACCURACY
We recognize the importance of maintaining accurate customer information that is provided to you in various forms, including account statements and billing statements. If you ever notice that your information is inaccurate, please contact us. Upon your notification we will correct any inaccuracies.
PROTECTING YOUR INFORMATION
There are a number of steps you can take to protect your information, including 1) before you reveal any personally identifying information, find out how it will be used and whether it will be shared with others; 2) pay attention to your billing cycles and follow up with creditors if your bills don’t arrive on time; 3) guard your mail from theft; 4) deposit outgoing mail in post office collection boxes or at your local post office; and, 5) put passwords on your credit card, bank and phone accounts. If you suspect that your personal information, including social security number or account information has been misappropriated to commit fraud or theft please contact: 1) your Convergent personal representative; 2) the fraud departments of each of the three major credit bureaus; 3) the creditors for any accounts that have been tampered with or opened fraudulently; and 4) your local police or the police in the community where the identify theft took place. You should also contact the Federal Trade Commission (FTC) at 1-877-IDTheft or at www.ftc.gov/bcp/edu/microsites/idtheft/.
LIMITING DIRECT MARKETING FROM OTHERS
If you wish to remove your name or reduce the amount of marketing mail or telemarketing calls that you receive, you may do so by notifying the following in writing:
Mail Preference Service
c/o Direct Marketing Association
P.O. Box 9008
Farmingdale, NY 11735-9008
Telephone Preference Service
c/o Direct Marketing Association
P.O. Box 90014
Farmingdale, NY 11735-9014