Sources and Categories of Personal Information We Collect
When you establish a relationship with us, you are requested to furnish personal and financial information to assist in assessing your financial objectives and goals. During the course of our relationship we may also collect a variety of personal information that may directly or indirectly identify you, including non-public personal information from other sources such as accountants, legal counsel, financial advisers, insurance agents, banking institutions, brokerage firms and others.
The specific types of personal information we collect depend on the product or service you have with us. This information can include name, telephone, address, date of birth, social security number, government identification, marital status, e-mail address, employment and banking information.
How is your Personal Information Used?
We will only use your personal information for the purpose of providing you with our investment services. In managing your investments, we may use your personal information to:
- monitor, audit, evaluate and otherwise administer our products and services;
- conduct business processing functions which may including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
- assist with the administrative, marketing (including direct marketing), planning, product or service development, quality control or research purposes of TCI and its contractors and service providers;
- communicate with you and respond to your inquiries;
- conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms;
- for other purposes required or authorized by law, including other purposes for which you have provided your consent;
- protect against identify theft and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other unlawful activity, claims and liabilities; and/or
- perform data analyses (such as market and customer research).
In addition to the above, we use personal information to comply with applicable legal requirements, carry out our contractual obligations and pursue our legitimate interests (such as managing our client relationships). Where required by applicable law, we obtain consent to process personal information.
In the event that we use personal information we collect for other purposes not identified above where direct client consent is required under applicable rules, laws and/or regulations we will provide specific notice at the time we collect such personal information.
Disclosure of Your Personal Information to Third Parties
It is the policy of TCI to restrict access to all current and former clients’ information to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services in furtherance of the client’s engagement of TCI. In that regard, TCI may disclose the client’s information:
- as previously authorized to disclose the information to individuals and/or entities not affiliated with TCI , including, but not limited to our client’s other professional Advisers and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, etc.);
- as required to do so by judicial or regulatory process; or
- as otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations.
The disclosure of information contained in any document completed by the client for processing and/or transmittal by TCI to facilitate the commencement/continuation/termination of a business relationship between the client and/or between TCI and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, record keeper, insurance company, etc.), including, but not limited to, information contained in any document completed and/or executed by TCI or the client in furtherance of the client’s engagement of TCI (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider.
TCI does not share your personal information with other financial companies or our affiliates or non-affiliates for marketing purposes.
To the extent permitted by the applicable law of your jurisdiction, in relation to your personal information, you may request:
- to have your personal information corrected, for example, if it is incomplete or incorrect;
- to opt out of receiving marketing communications at any time;
- the right to file a complaint with an applicable government regulator such as a Data Protection Authority.
In addition to the foregoing, if you are located in the European Economic Area (“EEA”), to the extent permitted by applicable law, in relation to your personal information, you may request:
- to access the personal information held by us about you;
- the right to restrict or object to the processing of your personal information, or request that your personal information be erased;
- the right to receive a copy of the personal information which you have provided to our firm, in a structured, commonly used and machine-readable format (known as “data portability”);
- to have a copy of the personal information we hold about you provided to you or another controller where technically feasible;
- to withdraw your consent where you have provided personal information voluntarily, or otherwise consented to its use.
Is your Personal Information Secure?
TCI continually updates and improves security standards and procedures to guard against anyone gaining unauthorized access to your Information, including through the Internet. TCI maintains appropriate physical, electronic, and procedural safeguards that comply with applicable legal standards to protect its clients’ personal information.
Retention and Processing of Personal Information
To the extent permitted by applicable law, we retain your personal information for the period necessary to serve the purposes for which we obtained it. We may also retain your personal information beyond such period in accordance with applicable laws, regulations, or another lawful basis, including but not limited to, compliance with our contractual obligations, legal obligations, regulatory obligations, legal claims, or another legitimate interest.
We may transfer the personal information we obtain about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. To the extent required by applicable law, when we transfer your information to recipients in other countries we will protect that information as described in this Notice.
If you are located in the European Economic Area (“EEA”), we will comply with applicable legal requirements regarding the provision of appropriate safeguards for the transfer of personal information to recipients in countries for which the European Commission has not issued an adequacy decision.
As identified under applicable law, the data controller for this Notice is TCI located at the address below.
We want to assure you that we are committed to maintaining the confidentiality, integrity and security of your personal information. The safeguarding of client information is an issue we take seriously; whenever information is used, it is done with discretion.
We have developed these privacy policies to protect our clients. These policies are for general guidance and do not constitute a contract or create legal rights and do not modify or amend any agreement we have with our clients.
Changes to this Notice
Whom can you contact at TCI?
If you have any questions regarding this Notice or would like to exercise your rights, you may contact our Chief Compliance Officer, Simone Gehner, using the information below:
TCI Wealth Advisors, Inc.
4011 East Sunrise Drive
Tucson, Arizona 85718
The following entity is also covered under this Notice:
TCI Foundation, Inc.