In order to provide you with a standard of service commensurate with your goals, we need to obtain certain information about your personal and financial circumstances and may gather the following information:
We use only lawful means to gather information and, ordinarily, will not have access to information from third parties other than those you authorize to disseminate such information to us.
These third parties may include:
We publish this policy in order to ensure that you understand what KL Winterbourne Associates do and why. It also serves to ensure that, in the event that you should wish to challenge us, you have the information you need about your rights. Because so much about the way we handle data is dependent upon your personal needs and circumstances, it is not practical to provide extensive detail about the manner in which we process personal data.
KL Winterbourne Associates takes your privacy very seriously. In the normal course of conducting our business, we will not disclose or share any personally identifying information with any third party without your full, written authorization. There are however, certain circumstances under which we will need to share personally identifying information about you with third parties.
An instance like this would occur if we needed to allocate some of your capital to a mutual fund provided by a third party. Also, we may need to disclose personally identifying information about you if we are compelled to by a legal court order.
KL Winterbourne Associates allocates significant resources to technological infrastructure designed to protect electronically-held information. Information held about you is stored on secure servers protected by hardware and software firewalls as well as with third-party cloud storage providers on encrypted servers.
KL Winterbourne Associates reserves the right to make amendments to this policy without the provision of notice. In the event that we decide to make an amendment to this policy, we will post the updated policy on our website ensuring that you are always aware of the personal information we gather, how we use it and under what circumstances we will disclose it.