GUARDHILL FINANCIAL LLC
Introduction and Applicability
This policy is adopted pursuant to Title V of the Gramm Leach Bliley Act of 1999 and applicable federal laws and regulations. As used in this policy, the terms “we”, “us”, and “our” refer to GuardHill Financial Corp.
This policy applies only to personally identifiable financial information (also known as nonpublic personal information) obtained by us in connection with financial products and services primarily for personal, family or household purposes (and not business purposes). We do not provide information to companies for the purpose of independent telemarketing or direct mail marketing of any products or services of those companies.
This policy takes precedence over any previous privacy policies issued by us. We reserve the right to change this policy at any time with notice as may be required under applicable law. The standards contained in this policy do not constitute a contract or create legal rights.
Information we collect
We collect nonpublic personal information about our customers from the following sources:
– Information we receive from our customers on applications and other forms;
– Information about our customers¹ transactions with us or other persons who are not members of our corporate family (“non-affiliates”);
– Information we receive from a consumer reporting agency (e.g., credit bureaus and others); and Information we receive from our customers by e-mail.
Information we disclose and to whom
We may disclose the nonpublic personal information we collect about our customers to nonaffiliates, as permitted or required by law.
We may disclose nonpublic personal information received from our customers on applications and other forms, such as the customer’s name and address, to nonaffiliated companies that perform marketing services on our behalf with regard to our own products or services.
We also may disclose nonpublic information about our customers to nonaffiliated financial institutions with which we have joint marketing arrangements or to companies with which we have outside service provider arrangements, as follows:
– Joint marketing providers: From time to time, we may carefully select joint marketing providers to offer our customers specialized financial services, such as mortgage life insurance. If appropriate, we may disclose to these providers information received from our customers on applications or other forms, such as the customer’s name and address.
– Outside service providers: From time to time, we may enter into arrangements with companies or firms whose expertise is essential for our own services to function properly or to complete transactions. For example, we may work with specialized firms that generate disclosures and forms that we provide to our customers. As permitted by law, we disclose to these service providers the customer information that is necessary to perform these functions.
These marketing companies and joint marketing and outside service providers are required by us to enter into written agreements with us to safeguard the confidentiality of our customers’ nonpublic personal information and use it only for authorized purposes.
We do not disclose any nonpublic personal information about our customers that otherwise would require us to notify our customers of their right to direct us not to share such information (i.e., opt out right).
Safeguarding Consumer Information
We protect consumer privacy by ensuring that only employees who have a business reason for knowing information have access to it. We have appointed a Consumer Privacy Coordinator who is responsible for maintaining internal procedures to ensure that our customers’ information is protected. For example, information in loan files can only be accessed by employees who work in the loan origination or loan operations departments. We require independent contractors and outside companies who work with us to adhere to our strict privacy standards. These parties may include your selling and listing realtor, surveyor, insurance company, lender, title company, appraiser, and underwriter. We use technological means (such as backup files, virus detection and eradication software, firewalls, and other computer software and hardware) to protect against unauthorized access or alterations to customer data.
We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic, personal information. If we change our policy or practice by, for example, adding a category of information that we will disclose to a third party, we will notify existing customers and give them an appropriate time period to opt out of the disclosure.
We will continue to prudently enhance and manage information security standards and procedures to ensure the security and confidentiality of customer information; protect against any unanticipated threats or hazards to the security or integrity of such information; and, protect against unauthorized access or use of our customers’ information.
Should you have any questions regarding this policy, please contact us:
GuardHill Financial LLC
Attn: Consumer Privacy Coordinator
140 East 45th St, 31st Fl
New York, NY 10017