Exeter Privacy Notice
Exeter Financial LLC (referred to as “EF”)
maintains physical, electronic, and procedural safeguards
that comply with federal standards to protect its
clients’ nonpublic personal information (“information”).
Through this policy and its underlying procedures,
EF attempts to secure the confidentiality of customer
records and information and protect against anticipated
threats or hazards to the security or integrity of
customer records and information.
It is the policy of EF to restrict access to all current
and former clients’ information (i.e., information
and records pertaining to personal background, investment
objectives, financial situation, tax information/returns,
investment holdings, account numbers, account balances,
etc.) to those employees and affiliated/nonaffiliated
entities who need to know that information in order
to provide products or services to the client. EF
may disclose the client’s information if EF
is: (1) previously authorized to disclose the information
to individuals and/or entities not affiliated with
EF, including, but not limited to the client’s
other professional advisors and/or service providers
(i.e., attorney, accountant, insurance agent, broker-dealer,
investment adviser, account custodian, etc.); (2)
required to do so by judicial or regulatory process;
or (3) otherwise permitted to do so in accordance
with the parameters of applicable federal and/or state
privacy regulations. The disclosure of information
contained in any document completed by the client
for processing and/or transmittal by EF in order to
facilitate the commencement/continuation/termination
of a business relationship between the client and
a nonaffiliated third party service provider (i.e.,
broker-dealer, investment adviser, account custodian,
insurance company, etc.), including information contained
in any document completed and/or executed by the client
for EF (i.e., advisory agreement, client information
form, etc.), shall be deemed as having been automatically
authorized by the client with respect to the corresponding
nonaffiliated third party service provider.
EF permits only authorized employees and affiliates
who have signed a copy of EF’s Privacy Policy
to have access to client information. Employees violating
EF’s Privacy Policy will be subject to EF’s
disciplinary process. Additionally, whenever EF hires
other organizations to provide services to EF’s
clients, EF will require them to sign confidentiality
agreements and/or the Privacy Policy.
Should you have any questions regarding the above,
please contact Stephen Harrison, Chief Compliance
Officer.
Exeter Privacy Policy
Pursuant to applicable federal and/or state privacy
regulations Exeter Financial LLC (referred to as “EF”)
is a financial institution that has determined to
keep confidential nonpublic personal information about
each EF client.
Nonpublic personal information is defined to mean
personally identifiable financial information that
is provided by a consumer to a financial institution,
results from any transaction with the consumer or
any service performed for the consumer, or is otherwise
obtained by the financial institution.
Personally identifiable financial information means
any information: (1) a consumer provides to a financial
institution to obtain a financial product or service;
(2) about a consumer resulting from any transaction
involving a financial product or service between a
financial institution and a consumer; or (3) a financial
institution otherwise obtains about a consumer in
connection with providing a financial product or service
to that consumer.
Attached hereto and made a part hereof is a copy of
EF’s Privacy Notice that is to be distributed
by EF: (1) initially: (a) to each existing EF client;
and (b) to each new client prior to or at the time
of establishing a “customer relationship”
with EF; and (2) annually thereafter for as long as
the client maintains its relationship with EF.
The purpose of EF’s Privacy Notice, Privacy
Policy as well as its underlying procedures is to
protect the confidentiality and security of its clients’
nonpublic personal information. The categories of
nonpublic personal information that EF collects from
a client depend upon the scope of the client engagement.
It may include information about the client’s
personal finances, information about the client’s
health to the extent that it is needed for the planning
process, information about transactions between the
client and third parties, and information from consumer
reporting agencies. EF has instituted certain technical,
administrative and physical safeguards through which
EF seeks to protect this nonpublic personal information
about current and former clients from unauthorized
use and access. First, technical procedures are used
in order to limit the accessibility and exposure of
client information contained in electronic form. Second,
administrative procedures are used in order to control
the number and type of employees, affiliated and nonaffiliated
persons, to whom customer information is accessible.
Third, physical safeguards have been established to
prevent access to client information contained in
hard-copy form. As illustrated above, EF realizes
the importance of information confidentiality and
security, and emphasizes practices which are aimed
at achieving those goals.
By executing this document in the space provided below,
you acknowledge, understand, and accept: (1) your
obligation to comply with EF’s Privacy Policy
as set forth on the attached Privacy Notice; (2) that
your knowing or reckless violation of this Privacy
Policy will result in discipline by EF, including
the potential termination of your employment; and
(3) that if you have any question(s) regarding any
aspect of the Privacy Policy, including exceptions
thereto, you shall immediately address such question(s)
with Stephen Harrison, Chief Compliance Officer, prior
to taking any action that could result in the violation
of the Privacy Policy. A complete copy of the applicable
federal and/or state privacy regulations is available
for your review upon request.
Copyright
2007, Exeter Financial, LLC, All Rights Reserved
