Privacy Policy

Disclosure of Holcombe & McGrath Privacy Policy

Holcombe & McGrath is committed to maintaining the confidentiality and security of the personal information of its clients. Keeping personal information confidential is one of our highest priorities. As a member of the financial services industry, we are sending this notice for informational purposes as required by law. This policy will be periodically updated and distributed to our clients.

Client Information We May Collect and Disclose

We collect and maintain only information necessary for us to be able to provide the services requested by our clients and to administer that business with us. We may collect nonpublic information from the following sources:

• Information we receive from applications or other forms, such as name, address, beneficiaries, assets, income and social security number; and
• Information about transactions with us or others, such as contribution amounts, account balances, or transactions completed with us.

Parties to Whom We May Disclose Client Information

We only share client personal information with nonaffiliated companies or individuals (such as brokers and custodians) that need this information in order to service client accounts on behalf of Holcombe & McGrath, or as required by law (such as governmental agencies). Holcombe & McGrath does not share nonpublic personal information about former clients unless required by law.

Access to Information

Holcombe & McGrath restricts access to client account personal information to those employees who need to know that information to perform client service functions. All such persons are educated on the importance of maintaining the confidentiality and security of the information and are required to abide by our policies.

Information Protection

Other than as described above, Holcombe & McGrath does not engage or provide personal nonpublic information to third parties service providers, including marketers or similar parties.

Holcombe & McGrath has adopted policies and procedures governing the protection, confidentiality, security, and integrity of nonpublic personal information, including the use of physical, electronic and procedural safeguards to protect nonpublic personal information.

Information for California Clients

In response to a California law, we automatically treat accounts with California billing addresses as if you do not want to disclose personal information about you to nonaffiliated third parties except as permitted by applicable California law. We will also limit the sharing of personal information about you with our affiliates to comply with all California privacy laws that apply to us.