Effective: September 1, 2015
Our Commitment to You
Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. HWM (also referred to as “we”, “our” and “us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you.
HWM does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information.
What information do we collect from you?
- Social security or taxpayer identification number
- Assets and liabilities
- Name, address and phone number(s)
- Income and expenses
- E-mail address(es)
- Investment activity
- Account information (including other institutions)
- Investment experience and goals
What Information do we collect from other sources?
- Custody, brokerage and advisory agreements
- Account applications and forms
- Other advisory agreements and legal documents
- Investment questionnaires and suitability documents
- Transactional information with us or others
- Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they receive from us.
Basics for Sharing
|Do we share?||Can you limit?|
Servicing our Clients
We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting.
HWM does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where HWM or the Client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes.
Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent(s) or representative(s).
Information About Former Clients
HWM does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients.
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.