First Financial Equity (FFEC) employees use information about you to respond to your needs and to provide you with information. We instruct our employees to use strict standards of care in handling the personal, confidential information of customers and remind them on a regular basis of their obligations with regard to the confidentiality of customer information.
How we Protect Confidentiality
FFEC uses procedural, physical, and electronic system safeguards to store and secure information about you in compliance with federal standards. Our systems protect your information from unauthorized access, alteration, and destruction. Access is permitted only to those individuals within our organization who need the information to perform their job responsibilities. FFEC may enter into agreements with other companies to provide services to us or to make products and services available to you. Under these agreements, the companies may receive information about you but they must safeguard this information and they may not use it for any other purposes.
How we obtain Your Information
In the normal course of business, FFEC collects, retains, and uses information about you to serve your financial needs, administer your account(s), and inform you of products and services that may be of interest. FFEC receives information about you from various sources, including information from:
• Your requests or applications for FFEC products or services, such as your name, assets, and income.
• Your transactions with FFEC.
FFEC asks that you review your information regularly to ensure that it is correct. Please contact your account representative if you need to correct or update your personal information.
Sharing Information for Legal and Routine Business Reasons
FFEC does not sell your personal information to anyone. FFEC may disclose or report information we have about you as permitted by law and when we believe in good faith that disclosure is required. For example, we may share information with regulatory authorities and law enforcement officials; provide information to protect against fraud and resolve customer disputes; report account activity to credit bureaus; share information with your consent, and give account information to check and statement printers and other service providers who work for us. The primary reason for sharing information about you is to increase your convenience in transacting business with us and to give you more financial service choices. Please note that FFEC will not share any information with its affiliate, FFEC Insurance Marketing, LLC, unless requested by the client. FFEC does allow account representatives access to their clients’ information if the account representative leaves FFEC and takes employment with another investment firm. Account representatives will not have access to their client information if they have been terminated for cause, or are exiting the investment business. FFEC will observe this procedure until we are advised of changes to the contrary under Regulation S-P.
FFEC does not retrieve account or personal information from visitors who browse the public areas of our Web sites. Clients who have the ability to access their accounts online are required to logon with their user name and individually selected password. Your password is known solely to you, the client, and should never be shared with anyone. You may change your password as often as you wish. For enhanced security, in August 2007 security enhancements were made to the customer web site. The first change limits the number of unsuccessful logon attempts to five. The second change imposes certain requirements for new passwords, which should further reduce the chance of any “hacker” guessing a client’s password.
When you access your account online, it is through a Secure Socket Layer-encrypted session between your browser and our servers. To ensure the highest level of security, we have installed VeriSign Global ServerIDs on each server. We will continue to enhance security procedures, as new technologies become available. Each time you access your account, please do not forget to log off when you are finished. This will prevent someone else from accessing your account if you leave your computer and your session has not automatically terminated.
Option to Opt Out and Change Notices
If for any reason at any time in the future, we find it necessary to disclose any of your personal information in a way that is inconsistent with this policy, we will give you advance notice of the proposed change and the opportunity to opt out of such disclosure.