Effective Date: 19/11/2015
Our practice, Charlotte Nanette Williams, is committed to protecting the privacy and security of your nonpublic personal information. As a registered investment advisory firm, we are bound by the Fiduciary Standard and by federal regulations, including the Gramm-Leach-Bliley Act, which governs how we collect, use, and safeguard your data.
1. Information We Collect
We collect nonpublic personal information about you from the following sources, which can be grouped into two main categories:
A. Nonpublic Personal Information (NPI)
This is information required to provide comprehensive financial services and advice. We collect this from:
- Information from Forms: Data you provide on advisory agreements, new account forms, or other documents (e.g., name, address, Social Security Number, date of birth, employment details).
- Information about Transactions: Details about your account activity with us or our custodians (e.g., account balances, investment holdings, transaction history, wire transfers).
- Information from Third Parties: Financial information received from your attorneys, accountants, or other authorized representatives with your consent.
B. Website and General Interaction Information
This is information collected from your online activity to ensure website security and improve service:
- Contact Information: Name and email provided when you fill out a contact form or subscribe to our blog.
- Technical Data: Your IP address, browser type, operating system, pages visited, and time spent on our website (collected via cookies and log files).
2. How We Use Your Information
We use your nonpublic personal information (NPI) only for legitimate business purposes necessary to provide our fiduciary services:
- To Service Your Accounts: To process transactions, provide investment advice, monitor portfolios, and execute our advisory agreement.
- To Comply with Legal Requirements: To comply with federal and state regulations, tax reporting, and respond to legal process (e.g., subpoenas).
- To Communicate: To send you required notices, annual privacy policy updates, and information relevant to your financial plan.
- To Protect Against Fraud: To verify your identity and protect against fraud, unauthorized transactions, or other liabilities.
3. Information We Disclose to Non-Affiliated Third Parties
We do not sell your personal information to anyone. We do not disclose any nonpublic personal information about our clients or former clients to anyone, except as permitted or required by law, or as necessary to provide services to you.
Permitted disclosures may include:
- Custodians: To firms like Schwab, Fidelity, or others who hold your assets, to execute transactions on your behalf.
- Service Providers: To third-party administrators who perform operational services on our behalf (e.g., portfolio reporting software, electronic filing services).
- Legal/Regulatory: To government agencies, regulators (SEC), and law enforcement, as required by law.
We enter into contractual agreements with all non-affiliated third parties that prohibit them from disclosing or using the information other than to carry out the specific purpose for which we disclosed the information.
4. Confidentiality and Security Measures
We recognize your trust is paramount. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.
- Employee Access: We restrict access to your NPI to those employees who need to know that information to service your account. All employees are trained on the importance of client confidentiality and privacy.
- Physical Security: Client records are stored in secure locations.
- Technical Security: We utilize encryption, firewalls, anti-virus protection, and secure data storage to protect electronic records from unauthorized access.
5. Your Right to Opt-Out
As an investment advisor, we do not share your nonpublic personal information with non-affiliated third parties for their marketing purposes. Because we only share information as strictly necessary to service your account or as required by law, the law does not require us to provide an opt-out choice for those specific disclosures.
6. How to Contact Us
If you have any questions about this Privacy Policy or the use of your information, please contact us:
Charlotte Nanette Williams 2901 S Bryant Ave, Edmond
OK 73013 Email: info@charlottenw.com Phone: +1-(405) 856-7870
