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Highland Capital uses the personally identifiable information that it gathers primarily
to communicate with you and, generally, it does not share this information with
third parties. Set forth below in this section 6 is our Privacy Policy which is
applicable to your use of the website and communications with Highland Capital.
We are required by federal regulations to adopt certain procedures designed to maintain
and secure the non-public personal information of its clients from inappropriate
disclosure to third parties. The following Privacy Policy is designed to meet the
standards set forth in the federal regulations and is applicable to your use of
the website.
We are committed to keeping personal information collected from potential, current
and former clients confidential and secure. The proper handling of personal information
is one of our highest priorities. We never sell information relating to our clients
to any outside third parties.
Client Information
We collect and keep only information that is necessary for us to provide the services
requested by our clients and to administer clients' business with us.
We may collect non-public personal information from clients or potential clients:
- From clients when they complete an application or other form, as well as through
written and electronic correspondence and telephone contacts. This includes information
such as name, address, social security number, assets, income, net worth, copies
of financial documents and other information deemed necessary to evaluate the client's
financial needs.
- As a result of transactions with the Company, its affiliates if any, or others.
This could include transactions completed with the Company or information received
from outside vendors to complete transactions or to effect financial goals.
Sharing Information
We only share the non-public personal information of our clients with non-affiliated
companies or individuals (i) as permitted by law and as required to provide services
to our clients, such as with representatives within our firm, securities clearing
firms, mutual fund companies, insurance companies and other financial services providers,
or (ii) to comply with legal or regulatory requirements. We may also disclose non-public
personal information to another financial services provider in connection with the
transfer of an account to such financial services provider. Further, in the normal
course of our business, we may disclose information we collect about clients to
companies or individuals that contract with us to perform servicing functions such
as:
- Recordkeeping
- Computer-related services
- Good faith disclosure to regulators who have regulatory authority over the company.
Companies hired to provide support services are not allowed to use personal information
for their own purposes and are contractually obligated to maintain strict confidentiality.
We limit use of personal information to the performance of the specific service
requested.
We do not provide personally identifiable information to mailing list vendors or
solicitors for any purpose. When we provide personal information to service providers,
we require these providers to agree to safeguard such information, to use the information
only for the intended purpose and to abide by applicable law.
Internet Access
We intend to provide a website on the Internet. Any information gathered through
our website will be treated in accordance with this Privacy Policy.
Employee Access to Information
Only employees with a valid business reason have access to clients' personal information.
These employees are educated on the importance of maintaining the confidentiality
and security of this information. They are required to abide by our information
handling practices.
Protection of Information
We maintain security standards to protect clients' information, whether written,
spoken, or electronic. We update and check our systems to ensure the protection
and integrity of information.
Maintaining Accurate Information
Our goal is to maintain accurate, up to date client records in accordance with industry
standards. We have procedures in place to keep information current and complete,
including timely correction of inaccurate information.
E-Mail
Should clients send us questions and comments via e-mail, we will share the client's
correspondence only with those employees or agents most capable of addressing the
client's questions and concerns.
We will retain all written communication until we have done our very best to provide
the client with a complete and satisfactory response. Ultimately, we will either
discard the communication or archive it according to the requirements under applicable
securities laws.
Please note that, unless expressly advised otherwise, our e-mail facilities do not
provide a means for completely secure and private communications between us and
our clients. Although every attempt will be made to keep client information confidential,
from a technical standpoint, there is still a risk. For that reason, please do not
use e-mail to communicate information to the us that is considered to be confidential.
If the client wishes, communications with us may be conducted via telephone or by
facsimile. Additional security is available to clients if they equip their Internet
browser with 128-bit “secure socket layer” encryption, which provides more secure
transmissions.
Disclosure of our Privacy Policy
We recognize and respect the privacy concerns of our potential, current and former
clients. We are committed to safeguarding this information. As a member of the financial
services industry, we are providing this Privacy Policy for informational purposes
to clients and employees and will distribute and update it as required by law. It
is also available upon request.
Last Updated: August 23, 2007
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