


Policy Notice
At Stephen Shipley, Inc. and our
family of companies our primary goal is to offer our customers
superior products and service. The foundation of this superior service is
trust. Our customers have elected to do business with us and we have an
obligation to safeguard that relationship by protecting their private
information. Our customers have given us private information expecting that we
will protect this information and at the same time offer them products and
services that they may need to meet their goals. We recognize this important
responsibility and we will accomplish both goals by adopting the following
policies.
Our Collection of Information About Customers
This policy covers customer information, which means
personally identifiable information about a consumer or a consumer's
current or former relationship with us. When customers establish a
relationship with us, we collect their personal private information. We
receive this information directly from the customers, from our affiliates
and from other sources such as credit reporting agencies. We will use this
information to help us administer and process the customer's orders. It is
our policy to collect only that information we need for specific business
purposes.
Sharing Information With Our Affiliated
Companies
In order to continue to offer products and services
to our customers, we will share our customer's transaction and experience
information among the affiliated companies of Stephen Shipley, Inc. to the
extent allowed under the law. Though customers will not be provided the
opportunity to opt-out of this information sharing, we will honor a
customers request not to receive marketing materials for products and
services.
Stephen Shipley, Inc. and its affiliates may
share other non-experience private information in order to perform
transactional assistance for our customers and other services as allowed
by law.
Restriction on Disclosing Information to
Parties Outside our Affiliated Companies
We will not disclose our customer's private personal
information we have collected to other companies unless:
- The customer requests and authorizes that we
provide this information to another party.
- The information is provided to a credit bureau or similar credit
reporting agency.
- The information is provided to help the customer complete a transaction
they initiated.
- We are required by law to furnish the information.
- We have a joint marketing relationship with another company in order to
offer the customer a product or service, and we require that company to
sign an agreement to protect our customer's private information. We will
limit the information we provide these companies to include only that
information we have gathered through our own experience with our
customers.
Disclosing Information to Other Outside Companies
Periodically, we will need to share our customer's
private information with outside companies; for example, companies that we
hire to maintain our computer systems and companies that perform data
processing. We will communicate our privacy commitment to these companies
and ask that these companies agree to safeguard customer information, use
the information only for its intended purpose, and not distribute it to
other companies unless it is necessary to complete the customer's order.
Providing Privacy Information to Customers and
Responding to Inquiries
Customers have the right to receive, and we have a
responsibility to inform customers of, our privacy policies and practices.
We will therefore provide this notice of our privacy policies in the form
of a Privacy Notice. The Notice will describe in detail the privacy
practices of the corporation.
Protecting Private Information
We will diligently protect our customer's
private information by establishing operational safeguards that will
create standards and procedures for the security of computer systems that
house private information to help prevent unauthorized access. We will
also periodically update and test the data processing systems and assure
the integrity of the information. We will allow access to our customer's
private information by only those employees or contractors who have a
business reason to access such information and will establish operational
procedures to safeguard private information from being released
accidentally or released to individuals that fraudulently attempt to
obtain the information. Also, we will train and educate all employees and
contractors on the importance of confidentiality and protecting customer
privacy. We will take appropriate disciplinary measures to enforce
employee and contractor privacy responsibilities.
