We do not disclose nonpublic personal information about our clients or former clients to third parties other than as described below.
We collect information about you (such as your name, address, social security number, assets and income) from our discussions with you, from documents that you may deliver to us and in the course of providing advisory services for you. We may use this information to provide advisory services to you, to open an account for you, to process a transaction for your account or otherwise in furtherance of our business. In order to service your account and effect your transactions, we may provide your personal information to our affiliates¹ and to firms that assist us in servicing your account and have a need for such information, such as a broker or fund administrator. We may also disclose such information to service providers and financial institutions with whom we have joint marketing arrangements. We require third-party service providers and financial institutions with which we have joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them. We do not otherwise provide information about you to outside firms, organizations or individuals except to our attorneys, accountants and auditors and as permitted by law. We expect to maintain certain nonpublic personal information for an indefinite period of time following the cessation of our business together.
We restrict access to nonpublic personal information about you to our employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with regulatory requirements to guard your personal information.
If unusual circumstances arise (beyond the disclosures for normal servicing referenced above) where we develop plans to disclose nonpublic personal information, customers will be contacted and notified of the situation and their right to “opt-out” of the disclosure. If a customer chooses to “opt-out” we will not disclose their nonpublic personal information as planned; we will honor this disclosure restriction once received and until the customer revokes it. A customer may also request in writing that we delete/destroy all nonpublic personal information; we will promptly honor your request where legally permitted to do so.
We urge all customers, and prospects, to carefully guard your personal information with special attention to your electronic footprint, safeguarding your identifications and your passwords in all of your endeavors including your interaction with us. Know your rights and protections in your jurisdiction. Please use the contact information below for any comments or questions.
¹ Contravisory Investment Management, Inc. has one affiliate (Contravisory LLC) due to common and equal ownership between William M. Noonan and Philip A. Noonan.
120 Longwater Drive, Norwell, Massachusetts 02061 T: 781-740-1786 F: 781-749-4910