Freeman Investment Management Co., LLC
Notice of Privacy Policy and Practices
Freeman Investment Management Co., LLC (Freeman) recognizes and respects the privacy expectations of our clients1 and is committed to safeguarding our customers’ nonpublic personal information. Federal law, the Gramm-Leach-Bliley Act has required that all financial institutions provide notice to consumer customers about the type of information the financial institution collects and with whom and under what circumstances the information is shared. We are providing this notice to you so that you will know what types of information we collect about individuals, such as yourself, who apply for or obtain our products or services, how we handle and protect such information, and the circumstances in which that information will be disclosed to third parties who are not affiliated with us. The provisions of this notice apply to former clients as well as current clients.
Information We Collect
We collect nonpublic personal information about you for business purposes from the following sources:
- Investment Advisory Agreements and other forms, which may include your name, address, social security number, income information, net worth, asset statement, tax circumstances and information about your investment goals and risk tolerance;
- Account History, including information regarding your account’s transactions which may include the parties to a transaction, the positions held or sold, and pricing; and
- Correspondence, written, telephonic or electronic between you, us and/or any service providers for your account.
“Nonpublic personal information” is nonpublic information about you that we obtain in connection with providing you with a financial product or service for your professional, business, personal, family, or household purposes.
Information Disclosure To Third Parties
We do not disclose any nonpublic personal information about you to non-affiliated third parties, except to service providers and as otherwise permitted by law. We do not sell any personal information about you to any third party.
In the normal course of business, personal information we collect about you, as described above, may be shared with financial service providers providing services on behalf of your account (including your broker, your custodian, your accountant, other investment advisers you may have, and any other service providers related to your account). We may disclose information we collect about you to nonaffiliated third party service providers as necessary to (i) effect, administer or enforce a transaction that you request or authorize, (ii) in connection with processing or servicing a financial product or service that you request or (iii) in connection with maintaining or servicing your account with the third party. For example, information may be disclosed to others to enable them to perform general administrative activities for us, to assist us in processing a transaction authorized or requested by you, to execute trades on your behalf pursuant to our investment advisory agreement, or to coordinate with the custodian that holds securities on your behalf.
We may also disclose personal information with non-affiliated entities and regulatory authorities as permitted by applicable law. For example we may disclose such information to cooperate with regulatory authorities and law enforcement agencies and as necessary to protect our rights and property.
Protecting Confidentiality And Security
Our goal is to maintain current, accurate and complete information about our customers. We have established procedures to investigate customer reports of incorrect information and to correct information when we determine it to be inaccurate.
We maintain physical, electronic, and procedural safeguards to protect the nonpublic personal information we have about you. We treat this information in a confidential manner. We restrict access to nonpublic information about you to employees who have an appropriate reason to access it, such as to administer your account or offer our products and services. We educate our employees on the importance of protecting the privacy and security of confidential personal information. When applicable, we require third parties with whom we share information to:
- maintain policies and procedures designed to assure only appropriate access to, and use of information about, our customers; and
- maintain physical, electronic and procedural safeguards that comply with federal standards to guard nonpublic information of our customers.
We reserve the right to change this privacy policy at any time and you will be notified if any changes occur.
1 For purposes of this notice, the terms “client” or “clients” includes both present and past clients of ours and individuals who have provided us with nonpublic personal information but have not become our clients.