Disclosures

Crewe, and the entire financial services industry, go to great lengths to protect the privacy of the personal financial information of our clients. At Crewe, we respect every individual’s right to privacy, and we have a long-established tradition of discretion for our clients’ personal privacy. We reinforce this respect daily in the way we routinely handle sensitive client information in our day-to-day operations.

The Gramm-Leach-Bliley Financial Services Modernization Act requires all financial institutions to disclose clearly, conspicuously, and annually to consumers and clients our policies for collecting and sharing nonpublic personal information. The following sets forth Crewe’s privacy policy. We will only share personal information with others as stated in this pledge unless we ask your permission.

When you establish a relationship with Crewe, you complete certain account documentation that includes personal information, including the following: name, address, telephone number, social security number, income, assets, liabilities, and investment experience. We are required by our regulators to obtain this information and we do not sell or otherwise provide this personal information to marketing firms. Such information may be shared with entities involved in servicing and administering accounts on behalf of Crewe; however, our obligation to protect your privacy extends to these entities. We will share your information only with those entities who have agreed to conform to our privacy standards and who are contractually bound by confidentiality agreements.

We do reserve the right to disclose the personal information of our existing and former clients when we believe that disclosure is required by law or regulation or is necessary to (i) comply with a request from a self-regulatory authority or other securities regulator or law enforcement agency, (ii) perform credit checks, (iii) collect or report debts owed to us, (iv) protect our rights, or (v) comply with a subpoena or other judicial process.

Our procedures to protect your privacy are generally dictated by our regulators’ standards to ensure the security and confidentiality of clients’ information, to protect against any anticipated threats or hazards to the security or integrity of such records, and to protect against unauthorized access to records that may harm or inconvenience the client.

We strive to maintain strict standards to protect your personal information. If you have any questions or concerns regarding this policy, please contact us at (385) 355-2700. In addition, it is important to us that we have accurate information about you. If you are a client and have a concern about your personal or account information or you want to correct, update, or confirm your information, please contact us.

Investment advisers are required by law to inform their clients of their policies regarding privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law. Federal law gives the customer the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information.

TYPES OF NONPUBLIC PERSONAL INFORMATION (NPI) WE COLLECT

We collect nonpublic personal information about you that is either provided to us by you or obtained by us with your authorization. This can include but is not limited to your Social Security Number, Date of Birth, Banking Information, Financial Account Numbers and/or Balances, Sources of Income, and Credit Card Numbers or Information. When you are no longer our customer, we may continue to share your information only as described in this notice.

PARTIES TO WHOM WE DISCLOSE INFORMATION

All Investment Advisers may need to share personal information to run their everyday business. In the section below, we list the reasons that we may share your personal information:

For everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus;
For our marketing – to offer our products and services to you;
For joint marketing with other financial companies;
For our affiliates’ everyday business purposes – information about your transactions and experiences; or
For non-affiliates to market to you.

Clients may opt out of sharing information for joint marketing to other financial companies, to our affiliates and to nonaffiliates. If you are a new customer we may begin sharing your information on the day you sign our agreement. When you are no longer our customer, we may continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

PROTECTING THE CONFIDENTIALITY OF CURRENT AND FORMER CLIENT’S INFORMATION

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law, including computer safeguards and secured files and building.

FEDERAL LAW GIVES YOU THE RIGHT TO LIMIT SHARING – OPTING OUT

Federal law allows you the right to limit the sharing of your NPI by “opting-out” of the following: sharing for non-affiliates’ everyday business purposes – information about your creditworthiness; sharing with affiliates who use your information to market to you; or sharing with non-affiliates to market to you. State laws and individual companies may give you additional rights to limit sharing. Please notify us immediately if you choose to opt out of these types of sharing.

DEFINITIONS

Affiliates – companies related by common ownership or control. They can be financial and non-financial companies.
Non-affiliates – companies not related by common ownership or control. They can be financial and non-financial companies.
Joint marketing – a formal agreement between non-affiliated financial companies that together market financial products or services to you.

Please call (385) 355-2700 if you have questions.
Your privacy, our professional ethics, and the ability to provide you with quality financial services are very important to us.

Download a copy of this policy here.