TCM has a tradition of integrity and service, which we believe includes protection of our clients' privacy. These are a part of our company's core values and are reflected in the way we serve our clients each day. Because of our role in handling your financial transactions, new federal legislation and regulations requires us to provide this privacy statement and notice to describe how your personally identifiable information, which includes client and financial information, may be collected and shared, as well as the steps we take to protect this information from unauthorized access.
This statement and the practices it describes, apply both to current and former clients effective July 1, 2001 and describes specifically how we handle nonpublic personal information for the financial services that any member of TCM provides for you personally.
We take great care to safeguard your nonpublic personal information and to ensure its accuracy.
- We limit employee access to nonpublic personal information to those who need to know this information in order to serve client relationships. Employees are educated about the importance of privacy in accordance with our employee confidentiality policies and procedures manual.
- We maintain physical, electronic and procedural safeguards designed to comply with all applicable regulatory standards to guard your nonpublic personal information.
- We strive to maintain complete, current and accurate information about you and your accounts. If you request a correction to our records, we will respond in a timely manner.
We collect nonpublic information so we are able to offer you products and enhance the service we provide to you. We collect and maintain nonpublic personal information in order to:
- Service your accounts and process your requests efficiently and accurately,
- Identify you and protect your accounts from unauthorized access or identity theft, and
- Inform you of financial services and choices that can meet your needs now and in the future.
This information may be collected from a variety of sources, including:
- Information we receive from you on account forms, questionnaires or subscription documents, such as your name, address, other contact and personal information and financial information,
- Information we receive through your transactions or experiences with TCM, such as your account balance and securities holdings, and
- Service providers who provide support services including bookkeeping and accounting functions to help us administer your financial relationship.
We do not share nonpublic personal information with nonaffiliated third parties unless it is related to the services you have asked us to perform, maintained in confidence, or as permitted by law.
- Non-public personal information may be shared with nonaffiliated third parties only under limited circumstances that may include:
- Our agents with whom we have confidential relationship, such as our counsel,
- Service providers who provide support services to help us administer your financial relationship, they may include bookkeepers, accountants, custodians, brokers, check printers, data processing companies, companies that prepare account statements, or companies that help us market our products to you,
- Other parties in the case of a sale, merger, exchange, transfer or other disposition of our services or business, and
- Other parties as permitted or required by applicable law. These parties may include, for example, government agencies in response to subpoenas and other legal processes, consumer reporting agencies or those with whom you have authorized us to share information.
These privacy guidelines represent the privacy practices of the individual members of TCM.