Martinelli Discenza
Martinelli Discenza Investment Counsel, Inc. maintains a written policy regarding the confidential nature of information about our clients. We use this notice as an opportunity to reaffirm and to explain to you our concern for the privacy of your personal financial information. We and our employees and affiliates need to know and retain certain personal and non-public financial information about individuals who are our existing clients, prospective clients and past clients (“You”) in order to provide services to you.
The information we may learn about you can include your name, address, social security number, assets, income, and financial and investing history. We gather information about you from discussions with you and from documents you may give us. We also learn information about you from conversations with and documents from your broker, custodian, trust officer, or other advisor. We receive and maintain additional information about your financial and investing activities in the course of providing investment advisory services to you.
We do not disclose the client information described above except as may be required or permitted by law. We use this information to begin an advisory relationship with you, to effect transactions in your accounts, to provide you with performance reports and other records or documents that you might request, and to offer you new financial products. In providing these services we may share your personal information with non-affiliated companies, such as brokers and custodians. We also may share your information with our legal representatives, such as our counsel and accountants, and with governmental and regulatory authorities, and certain industry organizations. We may include client names on a representative list, but only after the client has specifically consented to such inclusion. Finally, we may disclose client information to non-affiliated third parties who provide services to us and who agree to protect the confidentiality of your information, to use it for the limited purpose for which it is shared, and not to further disclose it to others except to fulfill that limited purpose.
Our policy restricts our internal use of nonpublic personal information to those employees who have a need to know that information in order to do their work, and we maintain physical, electronic and procedural safeguards to protect and secure your information. We will provide this policy to new individual clients when they open an account with us and annually after that. If we change our privacy policy to permit additional disclosures you will be notified in advance and, if required by law, you will be given an opportunity to opt out of such additional disclosure. At any time, we welcome your thoughts on this policy.