Effective: January 11, 2016
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. WorthFM (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.
WorthFM 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.
We do not share your information, unless it is part of servicing your accounts.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy.
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.
|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 goalsWhat 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|
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 maintain robust security practices to ensure your personal information is safe.
We require third parties that assist in providing our services to you to protect the personal information they receive from us.
An RIA shares Client personal information to effectlively implement its services. In the section below, we list some reasons we may share your personal information.
We need to share some of your data with our partners, such as TD Ameritrade.
We do not share your personal data with anyone else for marketing purposes.
Even if you leave us, we promise we still will never share your personal information.
|Basis 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.
WorthFM does not disclose, and does not intend to disclose, personal information with non-afffiliated 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 WorthFM 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
WorthFM 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.
|California||In response to a California law, to be conservative, we assume accounts with California addresses do not want us to disclose personal information about you to non-affiliated third parties, except as permitted by California law. We also limit the sharing of personal information about you with our affiliates to ensure compliance with California privacy laws.|
|Massachusetts||In response to a Massachusetts law, clients must “opt-in” to share non-public personal information with non-affiliated third parties before any personal information is disclosed. We may disclose non-public personal information to other financial institutions with whom we have joint business arrangements for proper business purposes in connection with the management or servicing of your account.|
|Vermont||In response to a Vermont regulation, if we disclose personal information about you to non-affiliated third parties, we will only disclose your name, address, other contact information, and general information about our experience with you.|
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.