Revision Date: April 20, 2017
Who We Are
You are receiving this notice as an existing or prospective client of Northern Capital Management, Inc. and/or Capital Retirement Plan Services, Inc. These companies are affiliates under common ownership and control. Clients do business with one or both and information collected is shared freely between them to provide efficient operations and streamline service for clients.
Facts about Privacy
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information.
What We Collect
The types of personal information we collect and share will depend on the services you receive. This information can include:
- Social security numbers and dates of birth
- Account numbers and balances
- Portfolio information (e.g. investment objectives, investment holdings, and transaction history)
- Federal and state income tax information
- Credit history and credit scores
- Employer Tax IDs and payroll information
- Contact information (e.g. address, phone number, and email)
- Estate planning and beneficiary information
- Other personal information (e.g. income, occupation, education, and interests)
How We Collect
We collect information initially when you sign up for services and on an ongoing basis when you open a new account, deposit money, process transactions and communicate with us to receive investment advice. We also collect information from the qualified custodian(s) of your account(s).
We Safeguard Your Information
To protect information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. Access to information is limited to authorized individuals who are trained to safeguard your personal information. Further, because identity theft is a serious concern to us all, we take additional steps to protect your identity by:
- Utilizing client identification and authentication procedures before initiating transactions.
- Ensuring a secure connection for the client login portion of our website (indicated by a padlock icon and web address beginning with https).
- Sending and receiving documents containing sensitive information through secure or encrypted methods.
- Training employees to safeguard your personal information and maintain confidentiality.
- We will never request account numbers, passwords or login information, social security numbers or dates of birth in an unsolicited telephone call or email communication to you.
Security is a Partnership
If you become aware of any suspicious activity relating to your account(s), please contact us immediately.
How We Share
All financial companies need to share client personal information to run our everyday business. In the section below, we list the reasons financial companies can share your personal information, what information we choose to share, and whether you can limit this sharing.
Reasons we can share your personal information Do We Share? Can you limit Sharing?
1.) For our everyday business purposes:
Such as to process your transactions, maintain your account(s); YES NO
respond to court orders and legal investigations or regulatory
audits (e.g. anti-money laundering, regulatory requests)
2.) For our marketing purposes:
To offer our products and services to you YES NO
3.) For joint marketing with other financial companies NO NO
4.) For our affiliates for everyday business purposes: YES NO
Information about your transactions and experiences
5.) For our affiliates for everyday business purposes: NO YES
Information about your creditworthiness
6.) For our affiliates to market to you YES YES
7.) For nonaffiliates to market to you YES YES
If you have any questions about our practices with respect to your personal information, please don’t hesitate to contact us by telephone at (509) 456-2526 or (800) 826-9803 or by email to email@example.com.
To Limit Sharing
You can contact our Chief Operations Officer Michelle Warner by phone at (509) 456-2526 ext. 17, email firstname.lastname@example.org, or complete the Opt Out form below to limit sharing. Our privacy policies and practices will continue to apply to your information even if you cancel services. If you have previously submitted an Opt Out form, we will continue to honor your request. If you are a new client, we begin sharing your information immediately. Evidence of your consent is documented in your advisory contract.