Privacy Notice
CMC Interactive, LLC & CMC Advisors, Inc.
CMC Advisors, Inc. (referred to as “CMC”) maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”). Through this policy and its underlying procedures, CMC attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.
It is the policy of CMC to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services in furtherance of the client’s engagement of CMC. In that regard, CMC may disclose the client’s information: (1) to individuals and/or entities not affiliated with CMC, including, but not limited to the client’s other professional advisors and/or certain service providers that may be recommended or engaged by CMC in furtherance of the client’s engagement of CMC (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, record keeper, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. The disclosure of information contained in any document completed by the client for processing and/or transmittal by CMC to facilitate the commencement/continuation/termination of a business relationship between the client and/or between CMC and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, record keeper, insurance company, etc.), including, but not limited to, information contained in any document completed and/or executed by the client in furtherance of the client’s engagement of CMC (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider.
CMC permits only authorized employees and affiliates who have signed a copy of CMC’s Privacy Policy to have access to client information. Employees violating CMC’s Privacy Policy will be subject to CMC’s disciplinary process. Additionally, whenever CMC hires other organizations to provide services to CMC’s clients, CMC will require them to sign confidentiality agreements and/or the Privacy Policy.
Privacy Policy
Pursuant to applicable federal and/or state privacy regulations CMC Advisors, Inc. (referred to as“CMC”) is a financial institution that has determined to keep confidential nonpublic personal information about each CMC client.
Nonpublic personal information is defined to mean personally identifiable financial information that is provided by a consumer to a financial institution, results from any transaction with the consumer or any service performed for the consumer, or is otherwise obtained by the financial institution.
Personally identifiable financial information means any information: (1) a consumer provides to a financial institution to obtain a financial product or service; (2) about a consumer resulting from any transaction involving a financial product or service between a financial institution and a consumer; or (3) a financial institution otherwise obtains about a consumer in connection with providing a financial product or service to that consumer.
Attached hereto and made a part hereof is a copy of CMC’s Privacy Notice that is to be distributed by CMC: (1) initially: (a) to each existing CMC client; and (b) to each new client prior to or at the time of establishing a “customer relationship” with CMC; and (2) annually thereafter for as long as the client maintains its relationship with CMC.
The purpose of CMC’s Privacy Notice, Privacy Policy as well as its underlying procedures is to protect the confidentiality and security of its clients’ nonpublic personal information. The categories of nonpublic personal information that CMC collects from a client depend upon the scope of the client engagement. It may include information about the client’s personal finances, information about the client’s health to the extent that it is needed for the planning process, information about transactions between the client and third parties, and information from consumer reporting agencies. CMC has instituted certain technical, administrative and physical safeguards through which CMC seeks to protect this nonpublic personal information about current and former clients from unauthorized use and access. First, technical procedures are used in order to limit the accessibility and exposure of client information contained in electronic form. Second, administrative procedures are used in order to control the number and type of employees, affiliated and nonaffiliated persons, to whom customer information is accessible. Third, physical safeguards have been established to prevent access to client information contained in hard-copy form. As illustrated above, CMC realizes the importance of information confidentiality and security, and emphasizes practices which are aimed at achieving those goals.
