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Privacy Policy Notice
Title V of the Gramm-Leach-Bliley Act (GLBA) generally prohibits any
financial institution, directly or through its affiliates, from sharing
nonpublic personal information about you with a nonaffiliated third party
unless the institution provides you with a notice of its privacy policies
and practices, such as the type of information that it collects about you
and the categories of persons or entities to whom it may be disclosed. In
compliance with the GLBA, we are providing you with this document, which
notifies you of the privacy policies and practices of High Falls Advisors, LLC.
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Information We Collect
We may collect "nonpublic personal information" about you from the following sources:
- Information we receive from you such as on applications, documents, or other forms.
- Information about your transactions we secure from our files, our affiliates or from others.
- Information we receive from third parties, such as a consumer reporting agency.
- Information we receive from others involved in your transactions, such as accountants and attorneys.
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Information We Disclose
We may disclose any of the above information that we collect
about our clients or former clients to our affiliates or to nonaffiliated
third parties as permitted by law.
WE DO NOT DISCLOSE ANY NONPUBLIC PERSONAL INFORMATION ABOUT YOU TO ANYONE
FOR ANY PURPOSE THAT IS NOT SPECIFICALLY PERMITTED BY LAW.
If you decide to become an inactive client, we will adhere to the privacy
policies and practices as described in this notice.
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Our Security Procedures
We restrict access to nonpublic information about you to those employees
who need to know that information to provide products or services to you.
We maintain physical, electronic, and procedural safeguards that comply with
federal standards to guard your nonpublic personal information.
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