Notice of Privacy Policy

January 10th, 2019

Middleton & Company recognizes that our relationships with current and prospective clients are based on integrity and trust. We place the highest value on the information you share with us, and we are committed to preserving your trust by respecting your privacy as outlined herein. Middleton & Company will not disclose your personal information to anyone unless it is required by law or at your direction. We will not sell your personal information. Middleton & Company will provide this Privacy Policy to all clients annually.

We want our clients to understand what information we collect, how we use it, and how we protect it responsibly.

Why We Collect Your Information

We gather information about you so that we can:

  • Design and implement the planning and investment-related services we provide to you; and
  • Comply with the Federal and State laws and regulations that govern us.

What Information We Collect and Maintain

In the normal course of business, we may collect the following types of “nonpublic personal information” about you:

  • Information from our initial meeting or subsequent consultations about your identity, such as your name, address, social security number, date of birth, and financial information.
  • Information about your financial status, needs, and objectives.
  • Information about your transactions with us (such as the types of investments you have made and your account status).
  • Information that we may receive from third parties with respect to your financial profile.

What Information We Disclose

We are permitted by law to disclose nonpublic information about you to unaffiliated third parties, such as service providers involved in servicing and administering products and services on our behalf. Our service providers include, but are not limited to, our internal staff, our auditors and our legal advisor. Additionally, in order for us to provide planning or investment management services to you, we may disclose your personal information in limited circumstances to various service providers, such as our account custodian, financial planning software provider(s), and our client relationship management (CRM) service provider. We may also consult with attorneys, accountants, insurance experts, and other professionals to provide financial planning services.

Otherwise, Middleton & Company will not disclose any personal information about you or your account(s) unless one of the following conditions is met:

  • We receive your prior written consent; or
  • We have documentation that the recipient is your authorized representative; or
  • We are required by law to disclose information to the recipient, such as for a subpoena or to satisfy a request from a regulator and/or to prevent fraud or money laundering.

Arrangements with companies not affiliated with Middleton & Company will be subject to confidentiality agreements. Information provided will be used only to provide the services specifically requested.

How We Protect Your Personal Information

Privacy has always been important to Middleton & Company. We restrict and limit access to client information only to those who need it to carry out their business functions. All original documents you provide to us will be returned or shredded; a copy will be kept in our electronic files. We maintain physical, electronic, and procedural safeguards to protect your confidential personal information. The same privacy policy also applies to former clients. We educate our personnel about safeguarding client information and preventing its unauthorized access, disclosure, or use. Personnel are required to acknowledge their acceptance and understanding of the Privacy Policy in writing.

If at any time you have questions regarding our privacy policies, please call or email George Middleton, Chief Compliance Officer, at george@middletonand.co or 360.524.3517.