We at Towneley Capital Management, Inc. have always placed an
emphasis on your privacy and the importance of safeguarding your nonpublic
personal information (“Personal Information”). This notice outlines our privacy
policies and describes how we use your Personal Information.
Personal Information We Collect
We collect Personal Information (such as your name, address and
social security number, etc.) from account applications or other forms you
complete, as well as from communications (electronic, telephone, written or in
person) with you or your authorized representatives (such as your attorney,
accountant, etc.). We also collect Personal Information about your accounts
(such as your account balances and transactions) with unaffiliated third party
broker dealers or custodians.
Personal Information We Disclose
We do not disclose any Personal Information about you to anyone
except: (i) to further the business relationship we conduct on your behalf, and
then only to persons necessary to effect the transactions and provide the
services that you authorize (such as custodians, broker dealers, trustees,
etc.); (ii) to persons assessing our compliance with industry standards (such
as regulators and consultants); (iii) to our attorneys, accountants, and
auditors (to the extent necessary); (iv) to protect against fraud, liability or
damages to property; (v) to respond to judicial process or (vi) as otherwise
permitted by law. We are permitted by law to disclose nonpublic personal
information about you to governmental agencies and other third parties in
certain circumstances (such as third parties that perform administrative
services on our behalf). These third parties are prohibited from using or
sharing the information for any other purpose.
Security and Confidentiality of Personal Information
We maintain physical, electronic and procedural safeguards that
comply with federal regulations to protect your Personal Information.
We restrict access to your Personal Information to those employees
who need to know that information to provide products or services to you. Our
employees are prohibited, either during or after termination of their
employment, from disclosing your Personal Information to any person or entity
outside Towneley Capital Management, Inc., including family members, except
under the circumstances listed above.
Our privacy policies apply to all current and former clients who
have a direct customer relationship with us. In our management, we may provide
your Personal Information to firms that assist us in servicing your account and
have a need for such information, such as a custodian. These service providers
agree to protect the confidentiality of your Personal Information and to use
the information only for the purposes for which we disclose the information to
you for choosing our investment advisory services. Please call us at (800)
545-4442, if you have any questions about our privacy policies.