Privacy

Commitment to Privacy

Clearbrook, LLC and its affiliates (“Clearbrook”) have a firm policy of protecting the confidentiality and security of information we collect about our clients. We do not share nonpublic personal information about you with unaffiliated third parties without your consent except for the specific purposes described below, in accordance with all applicable laws. Please read this policy carefully. It gives you important information about how we handle your personal information.

Use of Information

We limit the collection and use of nonpublic personal information to the minimum we believe is necessary to deliver superior service to you. Such service includes advising you about our products, services and other opportunities, maintaining your accounts with us, processing transactions requested by you or other persons authorized by you, and administering our business.

Collecting Information

We get most nonpublic personal information directly from you or your agents, when you apply for, access and use our and our business partners’ financial products and services – whether in person, by telephone or electronically. We may verify this information or get additional information from consumer reporting agencies or other sources. This nonpublic personal information may relate to your finances, employment, or other personal characteristics, such as your first and last name, address, phone number, social security number and email address, as well as accounts with us and transactions and interactions by us, with us, through us, or with others. We may also collect information about what you have entered into, viewed on and/or downloaded from our website.

Protecting Your Information

We employ elaborate physical, electronic, and procedural safeguards to protect any information our clients share with us. We limit access to your personal information to our employees who need to know that information to provide products or services to you. Employees who violate our Privacy Policy will be subject to disciplinary process. Such information may also be used to conduct the business of the Clearbrook companies.

Disclosure of Information

We do not disclose any kind of nonpublic personal information about our clients or former clients to anyone, except when we believe it necessary for the conduct of our business, or where disclosure is required by law. We may also provide any kind of nonpublic personal information to other Clearbrook companies to enable us to offer you their products or services. Except in those specific, limited situations, without your consent, we will not make any disclosures of nonpublic personal information to other companies who may want to sell their products or services to you. For example, we do not sell customer lists and we will not sell your name to a catalogue company or telemarketer.

Your Access to Information

Upon your written request, we will make available for your review any file we may maintain for your nonpublic personal information. However, nonpublic personal information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available to you.