E.T. Kelly & Associates LLC maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”). Through this policy and its underlying procedures, E.T. Kelly & Associates LLC attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information. It is the policy of ET Kelly & Associates LLC to restrict access to and/or the sharing of all current and former clients’ information (i.e., information and records pertaining to personal background [including social security number and address, financial situation, financial planning issues, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in furtherance of the client’s engagement of E.T. Kelly & Associates LLC. E.T. Kelly & Associates LLC shall disclose, as necessary, the client’s information: (1) to service providers in order to establish and maintain the client’s accounts and process transactions (1) required to do so by judicial or regulatory process; or (2) otherwise permitted to do so in accordance with applicable federal and/or state privacy regulations. However, E.T. Kelly & Associates LLC does not, and shall not, disclose or share information with any affiliated or unaffiliated persons, entities or service providers for marketing or any other purposes or reasons not referenced above.
