Title V of the Gramm-Leach-Bliley Act (”GLBA”) and the laws of the State of California generally prohibit Golden Gate Advisors, Inc. from sharing nonpublic personal information about our clients with a third party unless we provide this notice of our privacy policies and practices describing the type of information that we collect about our clients and the categories of persons or entities to whom that information may be disclosed. In compliance with the GLBA and California law, we are providing this document, which notifies our clients of the privacy policies and practices of Golden Gate Advisors, Inc.
Protecting the Confidentiality of Customer Information:
We take our responsibility to protect the privacy and confidentiality of client information very seriously. We maintain physical, electronic and procedural safeguards that comply with federal standards to store and secure information about our clients from unauthorized access, alteration and destruction. Our control policies, for example, authorize access to client information only by individuals who need access to do their work.
From time to time, we enter into agreements with other companies to provide services to us or make products and services available to our clients. Under these agreements, the companies may receive information about our clients but they must safeguard this information and they may not use it for any other purposes.
Who is covered by the Privacy Policy:
We provide our Privacy Policy to clients when they open a new account and annually after that. If we change our privacy policies to permit us to share additional information we have about our clients, as described below, or to permit disclosures to additional types of parties, the client will be notified in advance. This Policy applies to clients and former clients of Golden Gate Advisors, Inc.
Information We Have About You:
Golden Gate Advisors, Inc. receives information about our clients from various sources, including information from client transactions with us, such as account balances and mortgage information, and consumer reporting agencies as applicable.
Categories and Sources of Information Collected:
We collect nonpublic personal information about you from the following sources:
• Information that you provide us on applications and other forms.
• Information we receive from you on applications or other forms.
• Information about your transactions with us from the insurance companies we contact to underwrite your insurance.
• Information we receive from the Department of Motor Vehicles or other consumer reporting agencies.
• Information contained in medical records or from medical professionals that is related to insurance claims.
• Information about your transactions with us, our affiliates or others.
• Information we receive from a consumer reporting agency.
Information Golden Gate Advisors Shares:
Golden Gate Advisors, Inc. shares information it has about our client, as described above, to give our clients superior customer service, provide convenient access to our services and make a wider range of products available to you. Golden Gate Advisors, Inc. shares this information in various ways:
Sharing information for legal, joint marketing and business reasons:
We may disclose information we have about our clients as permitted by law. For example, we may share information with regulatory authorities and law enforcement official; provide information to protect against fraud; report account activity to credit bureaus; share information with your consent and give account information to statement printers and other service providers who work for us. We may also share information we have about you, as described above, with firms Golden Gate Advisors, Inc. hires to market Golden Gate Advisors, Inc. products and services or with financial institutions not within the Golden Gate Advisors, Inc. corporate family with whom we have agreements to provide our clients with offers of their financial products and services. For example, we may share information about clients with an insurance firm in order that the client may receive offers concerning various insurance products.
Sharing Information among our corporate organization:
Golden Gate Advisors, Inc. offers a wide array of financial products and services such as loans, deposits, check paying, investments, and insurance. We may share information we have about you, as described above, such as identification, application and credit bureau information, and transaction and account balance information among the Golden Gate Advisors, Inc. organization. Some of the benefits to the client are improved customer service and responsiveness and detection of unusual behavior to help prevent unauthorized transactions or fraud.
Information we may disclose to third parties:
We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law. We do not disclose information about you to third parties whose only use of the information is to market a product or service. However, in the course of our general business practices, we may disclose the information that we collect (as described above) about you or others without your permission to the following types of institutions for the reasons described below:
A. To a third party if the disclosure will enable that party to perform a business professional or insurance function for us.
B. To an insurance institution agent or credit reporting agency in order to detect or prevent criminal activity, fraud or misrepresentation in connection with an insurance transaction.
C. To an insurance institution, agent, or credit reporting agency for either this agency or the entity to whom we disclose the information to perform a function in connection with an insurance transaction involving you.
D. To a medical care institution or medical professional in order to verify coverage or benefits in order to inform you of a medical problem of which you may not be aware, or conduct an audit that would enable us to verify treatment.
E. To the California Department of Insurance or other insurance regulatory authority, law enforcement, or other governmental authority in order to protect our interests in preventing or prosecuting fraud, or if we believe that you have conducted illegal activities.
F. To a group policyholder for the purpose of reporting claims experience or conducting an audit of our operations or services.
Your right to access and amend your personal information:
You have the right to request access to the personal information that we record about you. Your right includes the right to know the source of the information and the identity of the persons, institutions or types of institutions to whom we have disclosed such information within 2 years prior to your request. Your right includes the right to view such information and copy it in person, or request that a copy of it be sent to you by mail (for which we may charge you a reasonable fee to cover our costs).
Your right also includes the right to request corrections, amendments or deletions of any information that is in our possession. The procedures that you must follow to request access to or an amendment of your information are as follows:
To obtain access to your information:
You should submit a request in writing to Golden Gate Advisors, Inc. 1990 N. California Blvd. Walnut Creek, CA 94596. The request should include your name, signature, address, social security number, telephone number, and the recorded information to which you would like access. The request should state whether you would like access in person or a copy of the information sent to you by mail. Upon receipt of your request, we will contact you within 30 business days to arrange providing you with access in person or the copies that you have requested.
To correct, amend, or delete any of your information:
You should submit a request in writing to Golden Gate Advisors, Inc. at the address above. The request should include your name, address, social security number, telephone number. the specific information in dispute, and the identity of the document or record that contains the disputed information. Upon receipt of your request, we will contact you within 30 business days to notify you either that we have made the correction, amendment or deletion, or that we refuse to do so and the reasons for the refusal which you will have the opportunity to challenge.
Our practices regarding information confidentiality and security:
We restrict access to nonpublic personal information about you to those employees who need to know that information in order to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.
Our policy regarding dispute resolution:
Any controversy or claim arising out of or relating to our privacy policy, or the breach thereof, shall be settled by arbitration in accordance with the rules of the American Arbitration Association, and judgment upon the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof.
The right to disclose information in unforeseen circumstances:
In connection with the potential sale or transfer of its interests, Golden Gate Advisors, Inc. and its affiliates (if any) reserve the right to sell or transfer your information (including but not limited to your name, address, age, sex, zip code, state and country of residency, and other information that you provide through other communications) to a third party entity that (1) concentrates its business in a similar practice, product or service; (2) agrees to be Golden Gate Advisors, Inc. successor in interest with regard to the maintenance and protection of the information collected; and (3) agrees to the obligations of this privacy statement.
Adopted July 2001
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