What types of nonpublic personal information about me does the Firm collect?
When you open an account, and when you are required to provide certain other periodic disclosures to the Firm, we collect the following types of information:
- Information provided by you on applications, investor questionnaires, agreements, or other forms, such as your name, address, date of birth, employment information, assets, income, and other similar information.
- Information about your transactions with us and with any affiliate.
What types of nonpublic personal information about me does the Firm disclose?
The Firm discloses the nonpublic personal information about you described above, primarily to provide you with the financial products or services you seek from us.
To what employees of the Firm is my nonpublic personal information disclosed?
The Firm discloses nonpublic personal information about you only to those employees of the Firm who need to know that information in connection with the servicing or processing of financial products or services requested by you, maintaining or servicing your account, or as required by law.
To what other firms is my nonpublic personal information disclosed?
The Firm discloses nonpublic personal information about you to nonaffiliated third parties whom the Firm utilizes in connection with the servicing or processing of financial products or services requested by you, or in connection with maintaining or servicing your account. For example, we provide information to nonaffiliated companies such as a prime broker, custodian, sub-investment advisor, administrative services provider, auditor, and counsel, if applicable. These companies acting on our behalf are required to keep your personal information confidential. The Firm also discloses nonpublic personal information to nonaffiliated third parties as required by law. These parties may include, without limitation, federal and state government/regulatory organizations such as the Internal Revenue Service, and the Securities and Exchange Commission. Disclosures for which you have provided your consent are also permitted.
The Firm may disclose information, as permitted by law, with our affiliated companies or representatives.
By sharing information about your accounts and relationships with our affiliated companies and representatives, we can offer you a broader range of financial services, improve your experience with us, and serve you more efficiently. The Firm does not sell your nonpublic personal information, or any other information about you or your account with us.
Will the Firm disclose my nonpublic information if I am no longer a customer?
The Firm does not disclose nonpublic personal information about former customers, except as required by law.
How does the Firm protect the confidentiality and security of my nonpublic personal information?
The Firm maintains physical, electronic, and procedural safeguards to protect non-public personal information. Account information is located on secure in-house servers with frequent password changes required. Security audits are performed routinely and remote access to business servers is strictly controlled. Servers have been enabled with technology to prevent unauthorized parties from viewing non-public personal information. Access to non-public personal information is limited to those employees requiring the information for client account maintenance. The Firm conducts internal audits of its business practices and procedures in order to protect personal information. All documents are kept on the premises in locked bins until an on-site shredding service disposes of them in a secure manner. Scanned documents are stored on secure servers.
The Firm conducts internal audits of its business practices and procedures so it can protect your personal information. In the event we need to dispose of documents containing your nonpublic personal information, all documents are kept on the premises in locked bins until an onsite shredding service with which we have contracted shreds all such documents and then disposes of them in a secure manner.
How do I limit or opt out of the sharing of information about me?
If you prefer, it is your right to limit the information we share about you with our affiliates and outside companies. You may exercise this choice by calling us at (845) 679-9166 (ask for Marilyn Marecek) or by emailing firstname.lastname@example.org. Your privacy choice will be applied to you as an individual and will automatically be extended to all of your accounts with us, as well as to any accounts you may have with any of our affiliates. Also, joint account holders may request the opt-out choice on behalf of another account holder. You may make your privacy choice at any time and it will remain in effect until you change it.
Miller/Howard Investments is obligated to comply with the specific state laws that apply to the disclosure or use of information about you.
Please note that we may continue to share some necessary information with our affiliates that identifies you (such as your name and date of birth), as well as information about your transactions. In addition, our affiliates may continue to use information they receive from us to perform services on our behalf, to respond to communications from you, as you authorize or request. We may also continue to share information about you with outside companies as permitted or required by law.