Effective Date: August 16, 2018
Trade PMR is committed to protecting the privacy and confidentially of your Nonpublic Personal Information. In this notice, the words “you” and “customer” are used to mean any individual who obtains or has obtained a financial product or service (Services) from Trade PMR as a provider of Services that involve compiling personal and sometimes sensitive information. Protecting the confidentiality of that information continues to be a top priority for Trade PMR. Whether you are a current, former, or potential customer, we believe that you should know about the information we collect, the measures we take to safeguard it, and the limited circumstances in which we may share your information.
- We collect only the customer information necessary to consistently deliver our Services to you. The information we collect and the extent to which we use it will vary depending on the Services for which you subscribe or purchase. Trade PMR collects information that helps us serve your financial needs, allowing us to provide a high level of customer service; develop and offer new Services for our customers and potential customers; and allowing us to fulfill any legal and/or regulatory requirements imposed on us. The information collected generally varies depending on the Services you subscribe to or purchase and may include, but are not limited to:
- Information provided on applications and related forms (i.e., your name, date of birth, home address, Social Security Number, account number, annual income and other Nonpublic Personal Information).
- Information obtained from other associations regarding any Service we may provide to you. (i.e., your name, date of birth, home address, Social Security Number, and other Nonpublic Personal Information).
- Third-party reports, such as consumer credit history, motor vehicle records, demographic and/or medical information, if relevant to your Service.
- Information about your relationship with us, such as Services purchased, and/or account numbers and balances.
2) We maintain safeguards to protect your privacy and information security. We have implemented security standards and processes including physical, electronic and procedural safeguards. We limit access to customer information to employees, your investment adviser or agent who may need it in order to fulfill their obligation to you for the Services for which you have subscribed or purchased. Employees of Trade PMR are trained to respect the confidentiality of your personal information and understand their duty to safeguard it.
3) We restrict the sharing of customer information for use in marketing. First and foremost, we do not sell or share customer information with outside parties who want to market their products or services to you. We may disclose your Nonpublic Personal Information to companies with which we share common ownership and with third-party institutions with which we have joint marketing agreements. We have confidentiality agreements in place with such third-party institutions.
As a provider of a wide variety of Services, we may identify opportunities to enhance customer service or to offer you additional Services offered by Trade PMR. However, we will not share information about you with others that could be used to make insurance underwriting or lending decisions about you, unless you direct us to or unless we notify you first and give you a chance to opt-out. In addition, we will not use certain Nonpublic Personal Information (such as income, account history or credit history) received from any affiliate in order to market its products or services to you unless you direct us to, or unless we notify you first and give you a chance to opt-out. Similarly, we will not share Nonpublic Personal Information with third-party financial services entities, such as banks, credit unions, credit union service corporations, insurance companies, or securities broker/ dealers, for purposes of joint marketing unless you direct us to, or unless we notify you first and give you a chance to opt-out.
4) We share customer information as necessary for business, regulatory, and servicing purposes. We will share customer information to facilitate or service a transaction you have requested, but only in accordance with all applicable federal and/or state laws. For example:
- In some cases, your information (i.e., your name, home address, date of birth, Social Security Number, account number and other Nonpublic Personal Information) may be provided to other affiliates of Trade PMR or to Trade PMR’s clearing firm to process or service a transaction you have requested or to facilitate enhanced customer serv
- We may share or exchange information with companies engaged to work with us, such as our clearing firm, third-party administrators and vendors hired to effect, administer or enforce a transaction or service that you request or authorize; to develop or maintain software; to perform marketing research; or to provide us with demographic information to develop marketing plans. We require these companies to maintain the confidentiality of customer information and use it only for the purpose for which it was prov
- We may provide information to reputable consumer reporting agencies in connection with your application or renewal of any Services subscribed or purchased.
- We may also share customer information in compliance with any federal or state law, statute or regulation (i.e., in response to a subpoena, to prevent fraud, and to comply with rules of, or inquiries from industry regulators or law enforcement).
- In addition, your investment adviser with whom you work with to obtain Services may use the personal information about you in his or her own files to advise you of other products or to help you with your overall financial plans. Such services provided by your investment adviser are exclusive of services provided by Trade PMR
We will reaffirm this policy as required by law, as long as you maintain an ongoing relationship with Trade PMR.
We recognize that your relationship with your investment adviser is important. If you are a participant of an employer sponsored plan, your investment adviser may be under an agreement that restricts the transfer of your personal information and/or your employer sponsored plan account to any new firm.
Safe Harbor: Trade PMR adheres to EU/US Safe Harbor principles with respect to covered data transferred from the European Union to the United States. More information about the Safe Harbor program can be found at http://www.export.gov/safeharbor.
Identity Verification: Trade-PMR, Inc. will use all means necessary to verify the information given on accounts, including the use of third-party credit agencies, to comply with all government and industry regulations. Such regulations may require Trade-PMR to report inadequate or incorrect customer information to proper governmental authorities.
Trusted Contact Person: If you elect to provide a Trusted Contact Person to Trade PMR, you authorize Trade PMR to communicate, verbally and in writing, with the Trusted Contact Person you’ve elected, or by other means which you have provided Trusted Contact Person information to Trade PMR. You understand that this authorization permits Trade PMR to discuss information about any and all accounts you have an interest in at Trade PMR, including information about account owners, as well as any account(s) for which the account owners have an interest in.
You understand that Trade PMR may contact the Trusted Contact Person provided by you for the following reasons: (1) if there are questions or concerns about your whereabouts or health status; (2) if Trade PMR suspects that you may be a victim of fraud or financial exploitation; (3) if Trade PMR suspects that you may no longer be able to handle your financial affairs; (4) to confirm the identity of any legal guardian, executor, trustee, authorized trader, or holder of a power-of-attorney; or (5) If Trade PMR has any other concerns or we are unable to contact you about the account(s) you have an interest in.
You further agree that: (1) the Trusted Contact Person authorization (“Authorization”) does not impose any obligation on Trade PMR to communicate with the Trusted Contact Person you have provided; (2) the Authorization does not authorize the Trusted Contact Person to make any investment decisions or transact business with Trade PMR on your behalf; (3) the authorization is optional and can be changed or withdrawn by you, in writing, at any time; (4) any named Trusted Contact Person you authorized will be eighteen years of age or older; (5) you release and discharge Trade PMR of all claims, causes of action, damages, losses, expenses, costs and liabilities of any kind that may arise out of, relate to, or are in connection with the release of, or failure to release, personal and/or account information to the Trusted Contact Person you have authorized.