Privacy Policy

PRIVACY POLICY STATEMENT

PWA is committed to safeguarding the confidential information of its clients. PWA holds all personal information provided to it in the strictest confidence. PWA may have relationships with other non-affiliated investment advisor firms, accounting firms, law firms, trust companies, custodians and other financial institution entities. Except as required or permitted by law, PWA does not share confidential information about clients with non-affiliated third parties. In the unlikely event there were to be a change in this fundamental policy that would permit additional disclosures of confidential client information, PWA will provide written notice to clients, who will be given an opportunity to direct whether such disclosure is permissible.

An Important Notice Concerning Customer Privacy

Customer Information Collected. PWA collects and develops personal information about clients and some of that information is non-public personal information (Customer Information). The essential purpose for collecting Customer Information is to provide and service the financial products and services clients obtain from the firm. The categories of Customer Information collected depend upon the scope of the engagement with PWA and are generally described below. As an investment advisor, PWA collects and develops Customer Information about clients in order to provide investment advisory services. Customer Information collected includes:

  • Information received from clients on financial inventories through consultation with PWA’s associated persons. This Customer Information may include personal and household information such as income, spending habits, investment objectives, financial goals, statements of account and other records concerning clients’ financial condition and assets, together with information concerning employee benefits and retirement plan interests, wills, trusts, mortgages and tax returns.
  • Information developed as part of financial plans, analyses, or investment advisory services.
  • Information concerning investment advisory account transactions, such as wrap account transactions.
  • Information about clients’ financial products and services transactions with PWA.

Data Security. PWA restricts access to Customer Information to those associated persons and employees who need the information to perform their job responsibilities within the firm. PWA maintains agreements, as well as physical, electronic and procedural securities measures that comply with federal regulations to safeguard Customer Information about clients.

Use and Disclosure of Customer Information to Provide Customer Service for Accounts. To administer, manage and service customer accounts, process transactions and provide related services for client accounts, it is necessary for PWA to provide access to Customer Information within the firm and to non-affiliated companies such as other investment advisors, other broker-dealers, trust companies, custodians and insurance companies. PWA may also provide Customer Information outside of the firm as permitted by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas.

Former Clients. If clients close an account with PWA, it will continue to operate in accordance with the principles stated in the Notice.

Requirements of Federal Law. In November of 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA). The GLBA requires certain financial institutions, including broker-dealers and investment advisors, to protect the privacy of Customer Information. To the extent a financial institution discloses Customer Information to non-affiliated third parties other than as permitted or required by law, customers must be given the opportunity and means to opt out (or prevent) such disclosure. Please note that PWA does not disclose Customer Information to non-affiliated third parties except as permitted or required by law (i.e., disclosures to service your account or to respond to subpoenas).