Privacy Notice

WELLFORD CAPITAL MARKETS LLC
Privacy Notice

Protection and Use of Private Information

Wellford Capital Markets prohibits unauthorized access by physical or electronic means to any of your Private Information. The only individuals who have authorization to access this Information on a regular basis are (a) your designated account representative and (b) officials of Wellford Capital Markets whose regular duties include processing and review of your account and reporting our progress to you and/or your legal representative.

Under no circumstances does Wellford Capital Markets ever provide any of your Private Information to telemarketing or other organizations for the purpose of marketing products and services not provided by us.

Permitted Use by Wellford Capital Markets LLC and Other Parties. The new law and regulations permit us to use your Private Information for a Permitted Use. A Permitted Use would include Wellford Capital Markets’ use of this information in our business under the controlled access circumstances described above. A Permitted Use also includes where, in the course of our business, we have the need to provide your Private Information to another company engaged in some aspect of our service to you. This company may be engaged in a related business such as mutual funds, annuities or other insurance product, consumer banking, mortgage lending, securities brokerage, investment advisory or tax, estate or financial planning. Or it may be engaged in some service such as a transfer agent, clearing or custodial firm, accounting or reporting, systems operation or marketing. When we do provide your Private Information, it is always under circumstances that require the other company, whether affiliated or not, to observe the same controls on access that we provide. Where the company is an affiliated company of ours, you have the right to “opt out” by preventing further disclosures of your Private Information among such companies. In addition, a Permitted Use includes disclosures to your legal representative, trustee or other fiduciary, or where we need to protect the confidentiality or security of Wellford Capital Markets’ records, or to prevent potential or actual fraud, unauthorized transactions, claims or other liability, for institutional risk control or resolving customer disputes or inquiries. Use is also permitted in connection with a proposed sale, merger or transfer of a business unit. Again, this information is provided under controlled circumstances which prevent its unauthorized use.

In addition to the above Permitted Uses, the law allows other Permitted Uses where we must provide your Private Information on request, for example, to insurance rate advisory organizations, funds guaranty agencies, agencies rating Wellford Capital Markets or assessing compliance with industry standards, attorneys, accountants and auditors of Wellford Capital Markets. Also, subject to the Right to Financial Privacy Act, disclosure is permitted on request by a law enforcement agency, regulator, self-regulatory agency or in a public safety investigation. Disclosure is also permitted on request to a consumer reporting agency in accordance with the Fair Credit Reporting Act, or to comply with federal, state or local laws, rules or regulations, including requirements of self-regulatory organizations or a subpoena or judicial process. In these circumstances, while we must comply with the legal requirements, Wellford Capital Markets makes every effort to protect the Permitted Use of your Private Information in such a way as to safeguard it from unauthorized use.

Your 30-Day Right to “Opt Out”
As a consumer and our customer you have the right under the law and the regulations to “opt out” of any use of your Private Information other than the Permitted Uses or sharing among affiliated companies as described above.
To “opt out” you must tell us by signing and returning this Notice WITHIN 30 DAYS OF THE DATE OF NOTICE SET FORTH ABOVE.

If you do nothing, we will continue to use and safeguard your Private Information as we have described above.

If there in any change in our use of your information (for example, where we might decided to use your Private Information for marketing or other purposes outside the uses described above or Permitted Uses) we will be required to send you another Privacy Notice and give you the right to “opt out” of the proposed use(s).