Maintaining the trust and confidence of our clients is one of our highest priorities. That is why we want you to understand how we protect your privacy when we collect and use information about you and the steps that we take to safeguard that information. This notice is provided to you on behalf of Executive Wealth Management, LLC, hereinafter referred to as “EWM”. Executive Wealth Management is a Registered Investment Advisor with the Securities and Exchange Commission (SEC) offering services to residents of the United States. Reference to registration does not imply any particular level of qualification or skill.
INFORMATION WE COLLECT:
In connection with providing investment advice, we obtain nonpublic personal information about you, including:
- Information we receive from you on account applications, such as your address, date of birth, social security number, occupation, financial goals, assets and income;
- Information we receive from you on our website, or contracted websites, such as your name and email address, home address, telephone number, date of birth, occupation and employment status, education financial goals, assets and income;
- Information about your transactions with us, our affiliates, custodians or others. EWM does not use information we collect to make any automated decisions through our services. We do not collect so called “special categories of personal data”.
cATEGORIES OF INFORMATION WE DISCLOSE:
CATEGORIES OF PARTIES TO WHOM WE DISCLOSE:
We disclose information regarding you or your account with us, only under the following circumstances:
- To your authorized Investment Advisor Representative and otherwise appropriate associated persons of EWM on a “need to know” basis;
- To our affiliate organizations EWM Tax Solutions, LLC and EWM Legal Solutions, LLC if we feel you can benefit from their services, during joint meetings or at your request;
- To our parent companies or their affiliates as needed and to the extent permitted by law;
- To entities that perform services for us or function on our behalf, including financial service providers, such as a clearing broker-dealer, investment company, or insurance company;
- To third parties who perform services or marketing on our behalf;
- By written authority, to your attorney, accountant or anyone else who represents you in a fiduciary capacity;
- To our attorneys, accountants or auditors; and
- To government entities or other third parties in response to subpoenas or other legal process as required by law, to comply with regulatory inquiries or to defend our firm against charges of fraud or illegal activity.
Our definition of personal nonpublic information does not include "aggregate" data. Aggregate data is information we collect about a group or category of services or users from which individual user identities have been removed; no personally identifiable information is included in aggregate data.
HOW WE USE INFORMATION:
Subject to legal exceptions and provided we can authenticate your identity, you will be given access to your personal information and entitled to challenge accuracy and completeness of the information, amending as appropriate. Information would be used among our family of companies, their affiliates, and the companies that perform support services for us, such as data processors, technical systems consultants and programmers, or companies that help us provide products and services to you for a number of purposes, such as:
- To comply with federal, state, and self-regulatory organization requirements;
- To protect your personally identifiable information and accounts from unauthorized access or identity theft;
- To communicate with you about your use of our websites and services;
- To process your requests such as securities purchases and sales;
- To establish or maintain an account with an unaffiliated third party, such as a clearing broker-dealer providing services to you and/or EWM;
- To service your accounts, such as by issuing checks and account statements;
- To keep you informed about financial services of interest to you;
- To request feedback and to enable us to develop, customize and improve the website and our publications, products and services; and
- For other purposes about which we notify you.
OUR SECURITY POLICY:
We restrict access to nonpublic personal information about you to those individuals who need to know that information to provide services to you and perform their respective duties. We maintain physical, electronic, and procedural security measures to safeguard personal, nonpublic or confidential client information. While we take reasonable efforts to guard personal information, we collect from you, including physical, electronic and procedural security measures, no security system is impenetrable. You can tell if your browser is in secure mode by the icons that appear on the top or bottom bar of your browser. In most browsers, a secure connection is indicated by a closed or locked padlock. If the padlock is open, your connection is not secure. If it is closed, you can double-click on the padlock to get more information about the security of the site you are visiting. Although we have implemented various measures designed to manage risks relating to cybersecurity events, if these systems are compromised, become inoperable for extended periods of time or cease to function properly, it would be necessary for us to make a significant investment to fix or replace them. The failure of our internet-based systems and/or the firm’s disaster recovery plan, for any reason, could cause significant interruptions in our operations and/or failure to maintain the security, confidentiality, or privacy of sensitive data, including personal information. We make every effort to prevent this from happening.
GENERAL SECURITY MEASURES YOU CAN TAKE:
We take reasonable measures to protect your physical and cyberstored personal information, but you also must play a role in ensuring that your personal information is secure and confidential. Here are five steps you can take to help us protect your information.
- Never tell anyone or otherwise share your account login information;
- Use hard-to-guess passwords;
- Change online password frequently;
- Be sure to log off online accounts before leaving your computer, especially public computers;
- Always close your browser after accessing accounts online.
OPT OUT NOTICE:
Opt-out notices typically apply to the sharing of information with unaffiliated third parties. Executive Wealth Management does not share your information with unaffiliated third parties. Executive Wealth Management only shares your information as outlined in this policy.
CLOSED OR INACTIVE ACCOUNTS:
We at EWM strive to meet and exceed our client’s expectations at all times. If there is ever a time when you are not satisfied with us, please direct complaints to:
Executive Wealth Management
135 W. North Street, Suite 1
Brighton, MI 48116
If we make any substantial changes in the way we use or disseminate confidential information, we will notify you.
Executive Wealth Management
135 W. North Street
Brighton, MI 48116