FWA respects the privacy of its clients and acts to meet the expectations of its clients in this regard. FWA does not sell your non-public personal information to anyone. Nor does FWA provide such information to others except for discrete and proper business purposes in connection with the servicing and management of accounts as discussed below.
Information FWA Collects
FWA typically receives personal information when you complete the paperwork required to become a Client. Your information may include:
In addition, FWA may collect non-public information about you from the following sources:
- Information FWA receives on Brokerage Agreements, Managed Account Agreements and other Subscription and Account Opening Documents;
- Information FWA receives in the course of establishing a customer relationship including, but not limited to, applications, forms, and questionnaires;
- Information about your transactions with FWA or others
Information FWA May Disclose
FWA works to provide products and services that benefit our customers. FWA typically does not share non-public client information with non-affiliated third parties (such as brokers and custodians) other than as necessary for FWA to provide agreed services and products to you consistent with applicable law. For example, FWA may disclose non-public personal information to other financial institutions with whom there are joint business arrangements for proper business purposes in connection with the management or servicing of your account. In addition, your non-public personal information may also be disclosed to you, persons FWA believes to be your authorized agent or representative, regulators in order to satisfy FWA’s regulatory obligations, and as otherwise required or permitted by law. Lastly, FWA may disclose your non-public personal information to companies FWA hires to help administrate our business. Companies hired to provide services of this kind are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. FWA limits their use of your personal information to the performance of the specific service(s) that are requested.
To repeat, FWA does not sell your non-public personal information to anyone.
Information About Former Clients
FWA does not disclose, and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer clients.
Confidentiality and Security
FWA employees understand the requirement to respect the confidentiality of customers’ non-public personal information and FWA periodically trains and educates employees in the handling and safeguarding of personal information in accordance with applicable laws, rules, and regulations. Additionally, FWA maintains physical, procedural and electronic safeguards in an effort to ensure the security and confidentiality of customer records and to protect the information from access by unauthorized parties. Employees who violate these policies are subject to disciplinary action, up to and including termination.
FWA understands the need to provide a secure environment for physical and electronic non-public client information. In addition to building security provided by building management, FWA has various controls in place to protect the security of the firm’s offices. Administrators in each office monitor visitors to the office and are trained on procedures for handling unauthorized individuals.
FWA regularly assesses its ability to protect the firm’s network against unauthorized access to its electronic data by outside parties, and has systems designed to prevent intrusions. Systems are monitored and any potential security breaches are reviewed immediately and resolved on a high priority basis.
FWA’s vendor websites utilized for reporting account information to FWA clients have security features designed to protect against unauthorized access to client information. FWA will perform assessments of the contract provisions and confidentiality and privacy policies of the service provider(s) to determine if appropriate safeguards for protecting customer information accessible to the provider are in place.
The CCO will annually test the information safeguards to ensure that they remain effective. The CCO will also attempt to annually identify reasonably foreseeable risks to information security and assess the effectiveness of existing safeguards for controlling these risks.