Maintaining the trust and confidence of our clients is a high priority. That is why we want you to understand how we protect your privacy when we collect and use information about you, and the steps that we take to safeguard that information. This notice is provided to you on behalf of Wellspring Financial Partners (“WFP”).
Information We Collect: In connection with providing investment products, financial advice, or other services, we obtain non-public personal information about you, including:
- Information we receive from you on account applications, such as your address, date of birth, Social Security Number, occupation, financial goals, assets and income;
- Information about your transactions with us, our affiliates, or others;
- Information about your visit to our website. We store that information in web server logs, which are records of the activities on our sites. The servers automatically capture and save the information electronically. The information we collect in web server logs helps us administer the site, analyze its usage, protect the website and its content from inappropriate use and improve the user’s experience.
- Information received from credit or service bureaus or other third parties, such as your credit history or employment status.
Categories of Information We Disclose: We may only disclose information that we collect in accordance with this policy. WFP does not sell customer lists and will not sell your name to telemarketers.
Categories of Parties to Whom We Disclose: We will not disclose information regarding you or your account at WFP, except under the following circumstances:
- To entities that perform services for us or function on our behalf, including financial service providers, such as a clearing broker-dealer, investment company, or insurance company;
- To comply with broker-dealer firms that have regulatory requirements to supervise certain representatives’ activities;
- To consumer reporting agencies;
- To third parties who perform services or marketing, client resource management or other parties to help manage your account on our behalf;
- To your attorney, trustee or anyone else who represents you in a fiduciary capacity;
- To our attorneys, accountants or auditors; and
- To government entities or other third parties in response to subpoenas or other legal process as required by law or to comply with regulatory inquiries.
How We Use Information: Information may be used among companies that perform support services for us, such as data processors, client relationship management technology, technical systems consultants and programmers, or companies that help us market products and services to you for a number of purposes, such as:
- To protect your accounts/non-public information from unauthorized access or identity theft;
- To process your requests such as securities purchases and sales;
- To establish or maintain an account with an unaffiliated third party, such as a clearing broker-dealer providing services to you and/or WFP;
- To service your accounts, such as by issuing checks and account statements;
- To comply with Federal, State, and Self-Regulatory Organization requirements;
- To keep you informed about financial services of interest to you.
Regulation S-AM: Under Regulation S-AM, a registered investment adviser is prohibited from using eligibility information that it receives from an affiliate to make a marketing solicitation unless: (1) the potential marketing use of that information has been clearly, conspicuously and concisely disclosed to the consumer; (2) the consumer has been provided a reasonable opportunity and a simple method to opt out of receiving the marketing solicitations; and (3) the consumer has not opted out. WFP does not receive information regarding marketing eligibility from affiliates to make solicitations.
Regulation S-ID: Regulation S-ID requires our firm to have an Identity Theft Protection Program (ITPP) that controls reasonably foreseeable risks to customers or to the safety and soundness of our firm from identity theft. We have developed an ITPP to adequately identify and detect potential red-flags to prevent and mitigate identity theft.
Our Security Policy: We restrict access to nonpublic personal information about you to those individuals who need to know that information to provide products or services to you and perform their respective duties. We maintain physical, electronic, and procedural security measures to safeguard confidential client information.
Cyber Security: Internal policies and procedures are in place to address cyber security. A copy of this policy is available upon request.
Departing Investment Adviser Representatives (“IARs”):
If your IAR’s affiliation with WFP ends and he or she joins a non-affiliated securities broker-dealer or registered investment adviser, WFP will permit the IAR to use certain client contact information to solicit clients to join the IAR’s new firm. The client contact information that the IAR may use is limited to your name, address, email address, phone number and account title.
Certain states have adopted a requirement for you to approve the sharing of information in advance, otherwise known as an “opt-in” choice. If you live in an “opt-in” state (e.g., California, Massachusetts, Maine, Alaska, North Dakota or Vermont), then WFP will require your consent to share your information with unaffiliated third parties who are not servicing your account. State requirements vary and may change without notice.
Succession Planning: In the event that the owner(s) of WFP retire, become incapacitated or perish unexpectedly, your information would be disclosed to an unaffiliated third party for the purposes of facilitating a business succession plan. A change in control of ownership of WFP would require your consent, as dictated by your signed agreement with WFP, in order to continue providing services to you.
Your Right to Opt Out: Federal privacy laws give you the right to restrict some sharing of your personal financial information. These laws balance your right to privacy with WFP’s need to provide information for normal business purposes. You have the right to opt out of some information sharing with companies that are (1) Part of the same corporate group as your financial company (or affiliates); or (2) Not part of the same corporate group as your financial company (or non-affiliates). Choosing to restrict the sharing of our personal financial information will not apply to (1) Information about you to firms that help promote and market the company’s own products or products offered under a joint agreement between two financial companies; (2) Records of your transactions–such as your loan payments, credit card or debit card purchases, and checking and savings account statements–to firms that provide data processing and mailing services for your company; (3) Information about you in response to a court order; and (4) Your payment history on loans and credit cards to credit bureaus. If you opt out, you limit the extent to which WFP can provide your personal financial information to non-affiliates.
Complaint Notification: Please direct complaints to: Deirdre Kochanski at Wellspring Financial Partners, 4703 E. Camp Lowell Drive, Suite 135, Tucson, AZ 85712; (520) 327-1019.