Notice of Privacy Principles

The following Privacy Principles sets forth our policy and procedures for protecting the non-public personal information of our clients. We want to assure all of our clients that whenever your personal information is used, it is done with discretion. The safeguarding of client information is an issue we take seriously at Penn Davis McFarland, Inc. (PDM). It is these Privacy Principles that guide us in serving the privacy needs of our clients.

  1. Recognition of a Client’s Expectation of Privacy: At PDM, we believe the confidentiality and protection of client information is one of our fundamental responsibilities. And while information is critical to providing quality service, we recognize that one of our most important assets is our clients’ trust. Thus, the safekeeping of client information is a priority for PDM.
  2. Use, Collection, and Retention of Client Information: The Company limits the use, collection, and retention of client information to what we believe is necessary or useful to conduct our business, provide quality service, and offer products, services, and other opportunities that may be of interest to our clients. Information collected may include, but is not limited to: name, address, telephone number, tax identification number, date of birth, employment status, annual income and net worth.
  3. Maintenance of Accurate Information: The Company recognizes that it must maintain accurate client records. Therefore, PDM has established procedures to maintain the accuracy of client information and to keep such information current and complete. These procedures include responding to requests to correct inaccurate information in a timely manner.
  4. Limiting Employee Access to Information: At PDM, employee access to non-public client information is limited to those with a business reason to know such information. Employees are educated on the importance of maintaining the confidentiality of client information and on these Privacy Principles. Because of the importance of these issues, all PDM’s employees are responsible for maintaining the confidentiality of client information and employees who violate these Privacy Principles will be subject to disciplinary measures.
  5. Protection of Information via Established Security Procedures: The Company recognizes that a fundamental element of maintaining effective client privacy procedures is to provide reasonable protection against the unauthorized access to client information. Therefore, The Company has established appropriate security standards and procedures to guard against any unauthorized access to client information.
  6. Restrictions on the Disclosure of Client Information: When it comes to sharing client information with unaffiliated companies, The Company places strict limits on who receives specific information about client accounts and other personally identifiable data. The Company may share information with such companies if they provide a product or service that may benefit our clients.Whenever we do this, we carefully review the company and the product or service to make sure that it provides value to our clients.
    We share the minimum amount of information necessary for that company to offer its product or service. We may also share information with unaffiliated companies that assist us in providing our products and services to our clients; in the normal course of our business (for example, with consumer reporting agencies and government agencies); when legally required or permitted in connection with fraud investigations and litigation; in connection with acquisitions and sales; and at the request or with the permission of a client.
  7. Maintaining Client Privacy in Business Relationships with Third Parties: If we provide personally identifiable client information to a third party with which we have a business relationship, we will insist that the third party keep such information confidential, consistent with the conduct of our business relationship.
  8. Disclosure of Privacy Principles to Clients: The Company recognizes and respects the privacy expectations of our clients. We want our clients to understand our commitment to privacy in our use of client information. As a result of our commitment, we have developed these Privacy Principles and made them available to our clients. Clients who have questions about these Privacy Principles or have a question about the privacy of their client information should call or e-mail us.

These Privacy Principles apply to individuals, and we reserve the right to change these Privacy Principles, and any of the policies or procedures described above. These Privacy Principles are provided to comply with our obligations under law and do not constitute a contract or otherwise create legal rights and do not modify or amend any agreements we have with our clients.

December 31, 2012