June 1, 2013
At Pitcairn, we consider your personal and financial information to be private and confidential; therefore, its safekeeping and proper use are a priority for us. We understand the value you place on security and the privacy of data that identify you and your account. In appreciation of these concerns, we hold our employees to strict adherence to our privacy practices.
To provide services to you, Pitcairn may share information about you both within the Pitcairn organization and outside Pitcairn with other companies as permitted by law. It is important to us that you understand our information safeguards, the types of information we maintain, what portion we share, and under what circumstances.
This notice describes the privacy practices of Pitcairn, including Pitcairn Trust Company and its affiliated entities, Pitcairn Company, Pitcairn Financial Group, Inc., Pitcairn Insurance Agency, LLC, Pitcairn Alternative Investment Fund, L.P., Pitcairn Private Equity Fund, L.P., Pitcairn Private Equity Fund II, L.P., and 165 Township Line, L.P. (collectively, “Pitcairn”), for financial products and services provided to individuals.
INFORMATION PITCAIRN COLLECTS
Pitcairn obtains and uses nonpublic personal information about you to conduct our business and to provide services to you, including:
- Information we receive from you (which may include, but not be limited to, your name, address, age, social security number, name of beneficiary) on applications and other forms, and surveys, or through your correspondence or communication with us including but not limited to through the mail, by telephone, facsimile or over the Internet
- Information about your transactions with Pitcairn and with other companies outside Pitcairn where you have authorized Pitcairn to receive such information
- Information about your family, assets, liabilities, sources and amounts of income, expenses, estate plans, gifts and other financial matters
INFORMATION WE SHARE WITHIN PITCAIRN
We may share all of the information we receive about you within Pitcairn, on a need to know basis, to service your relationship and to offer additional products or services, or to determine eligibility for offers of specialized investment products that can be offered only to certain qualified investors.
INFORMATION WE SHARE WITH OTHERS
Pitcairn does not disclose or sell nonpublic personal client information to anyone, except as permitted by law or with your consent. We are permitted by law to share all the information we collect about you with:
- Authorized service providers who need this information to perform services for us in connection with your account and Pitcairn’s financial products and services. These services include, but are not limited to, assembling and/or mailing client statements, aggregating client transactions from other financial providers, mailing mutual fund reports, and compiling income tax data for client tax returns
- Government entities pursuant to regulatory requirements or in response to subpoenas, or to prevent fraud
- Third parties to enable you to participate in securities class action lawsuits
- Consultants who need access to data in order to maintain the functionality and integrity of computer systems used by Pitcairn, and our web sites
This is not a complete description of the disclosures that we are permitted to make by law, but is meant to give you a general idea of situations in which Pitcairn may disclose information about you or your transactions.
OUR SECURITY PROCEDURES
At Pitcairn, employee access to your information is limited to those with a business need to know such information. We educate our employees on the importance of maintaining the confidentiality of such information, and hold them to strict compliance. In addition, we maintain levels of access, and electronic and procedural security measures.
We do not disclose nonpublic personal information about former clients except as permitted by law.
This notice updates and replaces any previous notices from Pitcairn about the privacy, security and protection of information. For additional information concerning Pitcairn’s privacy practices concerning the Internet, and to view the most recent version of this privacy notice, please go to www.pitcairn.com and click on “Privacy Notice.” You may have additional privacy protections under state laws. We may amend this privacy notice at any time, and we will inform you of any changes as required by law.
If you have any questions about this notice, please call your Personal Financial Manager.