Pursuant to applicable federal and/or state privacy regulations ATCapital Management Corp. (referred to as “ATCM”) is a financial institution that has determined to keep confidential nonpublic personal information about each AT client.
Nonpublic personal information is defined to mean personally identifiable financial information that is provided by a consumer to a financial institution, results from any transaction with the consumer or any service performed for the consumer, or is otherwise obtained by the financial institution.
Personally identifiable financial information means any information:
- A consumer provides to a financial institution to obtain a financial product or service;
- About a consumer resulting from any transaction involving a financial product or service between a financial institution and a consumer; or
- A financial institution otherwise obtains about a consumer in connection with providing a financial product or service to that consumer.
ATCM maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”). Through this policy and its underlying procedures, AT attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.
It is the policy of ATCM to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services to the client.
ATCM may disclose the client’s information if ATCM is:
- Previously authorized to disclose the information to individuals and/or entities not affiliated with ATCM, including, but not limited to the client’s other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, etc.);
- Required to do so by judicial or regulatory process; or
- Otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations.
The disclosure of information contained in any document completed by the client for processing and/or transmittal by ATCM in order to facilitate the commencement/continuation/termination of a business relationship between the client and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by the client for ATCM (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider.
The server on which the Web Site is located collects and saves only the default information customarily logged by web server software. Such information may include the date and time of visits, the originating IP address, and the pages and images requested.