Privacy Policy
Cutler Capital Management, LLC (Cutler) recognizes that safeguarding Personal Information (as described in the following section) about its clients is an essential commitment it makes and trust it holds. In this regard, Cutler has adopted certain policies and procedures concerning the use of Personal Information about its clients. These policies and procedures govern the activities of Cutler and its employees and strictly limit Cutler's ability to use or distribute Personal Information about its clients. This Privacy Notice identifies the Personal Information Cutler collects and holds, and describes how Cutler uses, shares and secures such information. Cutler does not disclose Personal Information about its current or former clients, other than as described below.
Why and How Cutler Collects Personal Information
Cutler collects Personal Information about its clients to:
- Accurately identify clients;
- Protect and administer records, accounts and funds; and
- Comply with certain laws and regulations.
The categories of Personal Information Cutler collects from clients depends upon the scope of its advisory relationship with the client. In the course of providing services to a client, Cutler may collect the following types of Personal Information:
- Information Cutler receives from a client on applications and other forms, such as the client's name, address, social security number, the types and amounts of investments and bank account information;
- Information a client provides to Cutler orally;
- Information a client directs or authorizes Cutler to obtain from third parties, such as investment, legal and insurance advisers or brokerage houses, banks and asset custodians;
- Information that Cutler generates to service a client's account, such as account statements and other financial information.
How Cutler protects Your Personal Information
People. Cutler educates its employees to treat Personal Information with care and work to limit access to this information to individuals who need it to perform their jobs, such as to conduct its business, service accounts or help clients pursue their financial objectives. Employees who have access to Personal Information are required to maintain and protect the confidentiality of that information.
Procedures. In compliance with applicable laws and regulations, Cutler maintains physical, electronic and procedural safeguards to protect Personal Information.
Security. Cutler takes such security measures as it deems appropriate to keep Personal Information confidential and secure against unlawful processing and to prevent loss, destruction or damage.
Guidelines for Disclosing Information
Cutler does not sell or rent Personal Information, nor does Cutler provide Personal Information to mailing list vendors or solicitors for any purpose. Cutler does not disclose, nor does Cutler reserve the right to disclose, any Personal Information about a client to anyone, except as permitted or required by law. For example, Cutler may be required to provide Personal Information to comply with investigations by regulatory authorities or law enforcement agencies or to protect against or prevent actual fraud or potential fraud, unauthorized transactions, claims or other liabilities. Cutler also may provide Personal Information to individuals authorized by a client, such as an attorney, accountant, and insurance agent. In addition, Cutler is permitted to provide Personal Information, such as a client's name, address and transaction history, to companies who are authorized service providers that assist Cutler with a variety of business activities and who need this information to perform services for Cutler in connection with a client's account and its services. These services include:
- Account administration;
- Data processing;
- Computer software maintenance and development;
- Transaction processing; and
- Marketing services.
All companies with whom Cutler does business are contractually obligated to comply with strict standards regarding the security and confidentiality of Personal Information. The Personal Information provided to such companies can only be used for the sole purpose of providing the service Cutler has requested the company to perform.
Accuracy of Personal Information
Cutler endeavors to keep its records of clients' Personal Information current and complete. If a client becomes aware of any discrepancies in their Personal Information, it is incumbent upon such client to notify Cutler so that Cutler may make the necessary corrections.
Ongoing Commitment
Clients will receive a current copy of the Cutler Privacy Notice on an annual basis. Cutler hopes that this information is useful to its clients. Confidentiality is the key to a strong relationship and Cutler is committed to protecting client privacy.
Former Clients
Cutler does not disclose Personal Information about former clients, except as permitted or required by law.
Contact
If you have any questions about this privacy policy, you can contact Cutler Capital Management, LLC, 306 Main Street, 2nd Floor, Worcester, MA 01608-1518
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