December 28, 2020
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), investment portfolio analysis and management tool 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