Policy on Protection of Consumer Information and Records
Perlinski & Associates (“P&A”) is a broker/dealer and member FINRA and is required to meet the requirements of the SEC Regulation S-P, “Privacy of Consumer Financial Information” (“Privacy Act”).
In part, the Privacy Act requires that each broker/dealer adopt policies and procedures that address the protection of customer information and records.
In order to comply with SEC Regulation S-P, P&A is providing you with this statement regarding its policies on the handling of confidential consumer information.
Perlinski & Associates and Perlinski & Company (“The Perlinski Companies”) receive non-public information (“NPI”) in the course of their business. This includes subscription documents and questionnaires that have been filled out by its investors. These may contain social security numbers, home addresses, annual income, net worth, education background, Employer Identification Numbers and other related data that is essential for P&A to have in determining the suitability of the investors.
The Perlinski Companies may use this information in order to develop, offer, and deliver products and services; respond to inquiries from you; or to fulfill legal and regulatory requirements. We do not disclose/share any NPI of our customers or former customers with any unaffiliated third party unless:
- It is necessary to fulfill a transaction or service request related to your account(s)
- We are required to do so by a regulator, a court of competent jurisdiction or applicable law
- It is by customer request
As this is our practice, The Perlinski Companies are not required to have “Opt-out” provisions or methods per the exemptive relief provided under section 248.13 of the Gramm-Leach-Bliley Act.
We restrict access of NPI to required personnel in the provision of requested services and maintain physical, procedural and electronic safeguards that comply with federal standards. The Perlinski Companies’ employees are initially and continually alerted to the fact that we obtain confidential information about its investors which must be held in the strictest confidence.
The Perlinski Companies restrict access to anyone’s personal information to those of our employees who need to know that information to provide products or services to our customers. The Perlinski Companies maintain physical, electronic, and procedural safeguards to guard customers’ NPI. These safeguards include keeping all confidential information on our premises in files that are locked or manned at all times, maintaining a strict confidentiality policy, and discussing our confidentiality policies at company meetings, such as the Annual Compliance Meeting.
Please do not hesitate to contact Perlinski & Associates at 949.481.5482 or at info@perlinski-associates.com if you have any questions regarding the protection of your confidential information