NOTICE OF PRIVACY POLICY
PITCAIRN
June 1, 2010
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 Financial
Group, Inc., Pitcairn Company, Pitcairn Group L.P., Pitcairn Insurance
Agency, LLC, Pitcairn Alternative Investment Fund, L.P., Pitcairn
Private Equity Fund II, L.P., and Pitcairn Private Equity Fund, 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.
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