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PRIVACY NOTICE
WALT ST Investment Management, Ltd. "WSIM", as a Registered Investment Advisor is required by Federal Regulation or disclose to you, the customer, how it protects your personal information. WSIM takes this responsibility very seriously, and we commit to protect your privacy and the confidentiality of your personal financial information. In regards to privacy we have established the following policies and procedures:
COLLECTION OF PERSONAL INFORMATION
The information we collect, and the extent that we use it, will depend greatly on the specific services that you have requested from us to provide on your behalf. The information may include information that we collect in personal interviews (or information you have provided to other investment professionals that use programs that we sub-advise). Information may include: name, address, social security number, date of birth, telephone number, current investments (and tax basis), income, total assets, tax bracket, liquidity, insurance policies, real estate holdings, wills, trusts, tax returns.
PROCEDURES TO SAFEGUARD YOUR PERSONAL INFORMATION
We have instituted electronic physical and procedural security measures and processes to ensure that access to your personal information is protected. Furthermore, access is limited to employees and under certain circumstances Investment Consultants that need the information to do their job in servicing you as the client.
SHARING CUSTOMER INFORMATION
As a policy WSIM will not under any circumstances, sell lists of our customers or disclose any of their personal information, to any marketing company. We will share information with other entities only for the following reasons: (1) When it is necessary to disclose information to third-parties to effect, administer or enforce a transaction that you request and or authorize; (2) When we provide information we collect as part of your new paperwork to TD Waterhouse or other custodian; (3) When we are required by law or regulation to disclose information to third parties - for example, in response to a subpoena; to prevent fraud; and to comply with the rules or inquiries from industry regulators.
Maintaining customer trust is of utmost importance at WSIM. We constantly strive to meet your needs while upholding the privacy policies. We also expect the same level of professionalism from any of our strategic partners. We will reaffirm this policy with you on an annual basis, in writing.
Note: For purposes of this policy "you" and "customer" refers to any individual who is receiving investment advisory services from WSIM.
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