This Notice explains the policy of Williams, Jones & Associates, LLC ("WJA", "we","our", or "us", as the case may be) on collecting and managing information about its customers, and how WJA protects the security and confidentiality of its customer information. This Notice is provided to you as required by federal laws and regulations. WJA considers customer privacy to be fundamental to our relationship with our clients. We are committed to maintaining the confidentiality, integrity, and security of your personal information. It is our policy to protect the personal and financial data entrusted to us by both current and former clients.
Information We Collect About You
In the course of providing investment management services to you, it is necessary for WJA to collect personal information about you. WJA may collect information about you to help identify you and service and manage your account. Some of this information is considered "personally identifiable financial information" or "nonpublic personal information."
WJA collects nonpublic personal information about you from the following sources:
Information provided by you on applications and other forms or through other interactions with WJA or someone on your behalf (for example, your name, address, social security number, income, assets and debt).
Information that you provide to us orally.
Information received from the custodian of your account[s] with us.
Information about your transactions or experiences with WJA or other companies (for example, your account balance, payment history, parties to transactions and account activity).
Information from other outside sources that may be obtained when verifying the information you provide on an application or other forms (for example, from your current or past employers, or from other institutions where you conduct financial transactions).
If you use our web site, information from your browser including your IP address and the web page you accessed.
Information We Disclose
WJA does not share or disclose any non-public personal information about you to anyone, except pursuant to government regulations, as required by law, or as authorized by you, and to conduct our business in accordance with our fiduciary responsibilities to you. We may disclose that information to unaffiliated third parties, such as transfer agents, broker-dealers, or custodians, only as permitted by law and as needed for us to provide agreed upon services to you.
WJA Company collects non-personal information in order to personalize your experience on the Site, diagnose problems with our server, and to administer the Site. WJA may analyze non-personal usage data and develop reports generated from the server's log files. WJA may use this information for marketing purposes and to enhance the Site's features and functionality. WJA does not share non-personal statistics with others outside of WJA.
To administer the Site and enhance our Services, WJA Company collects and analyzes statistical non-personal information. This data may include:
the name of the domain you used to access the Internet;
the date and time of your visit;
the type of browser software and computer hardware you used;
the pages you visited; and
the address of the web site you came from when visiting the Site.
Lastly, we may collect IP addresses. An IP address is a number that is automatically assigned to your computer whenever you are navigating the Internet. Internet servers automatically identify your computer by its IP address.
If WJA decides to change its policy on sharing or disclosing information, we will inform you first and give you an opportunity to decline or "opt-out."
Parties Who Receive Information From Us
Certain third parties may be given access to your nonpublic personal information in certain circumstances as discussed above. For example, WJA may share information as follows:
to give account information to printers and other service providers who work for WJA;
to provide information to protect against fraud;
to perform a transaction or service for you, such as transfer agents, broker-dealers and custodians;
with your consent; and
with regulatory authorities and law enforcement officials.
Nonpublic personal information disclosed under these circumstances is limited to the specific information required, and only for the purpose authorized.
How We Protect Your Information
WJA restricts access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. WJA uses commercially reasonable physical, electronic, and managerial procedures to maintain the confidentiality of your information on the Site. The Site uses security measures to safeguard your valuable data against loss, misuse and alteration while under our control. Our Site and servers are protected using encryption and other standard industry practices. We review and update web security and security procedures regularly. WJA informs all employees of their obligations to protect your information.
All account statements, reports, information, and other data made available for download by WJA reside on a secure server and are encrypted. Although WJA exercises reasonable care to maintain the confidentiality of your data, no transmission over the Internet can be guaranteed to be 100% secure and we cannot guarantee that the personal information you submit to us or any account statements, reports, information or other data will be free from unauthorized third party intrusion or interception. You therefore understand and agree that all information that you submit to WJA or download from the Site is done so at your own risk.
WJA Company is Not Responsible for the Privacy Policies and Procedures of Third Party Web Sites.
You should be aware that when you are on the Site, you may be directed to other websites that WJA does not control. These other websites may send their own cookies, collect data or solicit personal information. WJA is not responsible for the privacy practices of third party websites.
Protecting the Accuracy of Your Information
It is important that your account information be kept accurate. If you discover that the account information WJA has is inaccurate, incomplete, or not current, please write to us at 717 Fifth Avenue, 11th Floor, New York, New York 10022, phone us at 212-935-8750, or e-mail us at firstname.lastname@example.org. We will promptly investigate and correct or update any inaccuracies.
Protecting Your Privacy On-line
If you are just browsing through the WJA web site, you remain anonymous. Although the fact that someone has viewed the web site may be noted, WJA does not use "cookies" to collect identifying information on visitors to its web site.
If you send information to WJA on-line (over the Internet), WJA may collect the data you send, such as application information and e-mail correspondence. WJA retains this information as long as is required under applicable federal law.
Only those individuals who need to have access to your information are authorized to do so. WJA maintains commercially reasonable physical, electronic and procedural safeguards to protect its customer data and records. WJA also requires that any outside companies that work with WJA to manage your information maintain appropriate safeguards to protect customer data and records. WJA uses a range of internet security measures, such as firewalls that act as barriers between its network and others. Our on-line account access offers security measures including password protection with timeouts and lockouts. Information transmitted while accessing account information or applying on-line is protected by Secure Socket Layer (SSL) technology (a leading security protocol for data transfer on the Internet). The SSL technology scrambles, or encrypts, your account information as it moves from your PC's browser to the computer systems we use. However, messages you send to WJA by e-mail are not secure. If you need to send WJA confidential information other than by way of an on-line application, it is recommended that you write to us or telephone us.
You can also help maintain the security of your account information by not disclosing your password to anyone, by changing your password regularly, and by remembering to log off.
WJA does not knowingly market to children or solicit data from children.
Kids under 13: Do not send any information about yourself to us, including information such as your name, address or e-mail address. We do not knowingly collect personally identifiable information from children under age 13. In the event that we learn we have collected any personal information from a child under the age of 13 without verification of parental consent, we will delete that information from our database as quickly as possible.
717 Fifth Avenue
New York, New York 10022
or phone us at 212-935-8750