Privacy Policy

Carty, Harding & Hearn Inc. recognizes and respects the privacy expectations of its clients and is committed to safeguarding its clients “Nonpublic Personal Information” which is nonpublic information about a client the Account Representative obtains in connection with providing a client with a financial product or service for a client’s personal, family, or household purposes. These privacy disclosures apply to former and current clients, and to individuals who have provided the Account Representative with Nonpublic Personal Information but who have not become customers.

INFORMATION COLLECTED

The Representative collects client information from the following sources: (1) information on account document’s or other forms, which may include a client’s name, address, tax identification number, age, marital status, number of dependents, assets, debts, income, employment history, beneficiary information and personal bank account information:(2) information from the client’s transactions with the Representative, such as account history or balance; and (3) correspondence, whether written, telephone or electronic, between the client and the Representative.

INFORMATION DISCLOSED

The Representative does not disclose any Nonpublic Personal Information about a client to non-affiliated third parties, except to service providers and as otherwise permitted by law. In the normal course of business all of the Nonpublic Personal Information that the Representative collects about a client, as described above, may be shared with other persons who provide services in connection with the account (including brokers, administrators, custodians, accountants or attorneys, as well as any other service providers for the account). The Representative may also disclose personal information with non-affiliated entities and regulatory authorities as permitted by applicable law. The Representative may disclose such information to cooperate with the regulatory authorities and law enforcement agencies and as necessary to protect the Representative’s rights and property.

ANTI-MONEY LAUNDERING REQUIREMENTS

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THE USA PATRIOT ACT

The USA Patriot Act is an acronym for Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism. The USA Patriot Act was passed by Congress as a response to the terrorist attacks on September 11, 2001.

WHAT IS MONEY LAUNDERING?

Money laundering is the generic term used to describe the process by which criminals disguise the original ownership and control of the proceeds of criminal conduct by making such proceeds appear to have derived from a legitimate source. The processes by which criminally derived property may be laundered are extensive. Though criminal money may be successfully laundered without the assistance of the financial sector, the reality is that hundreds of billions of dollars of criminally derived money is laundered through financial institutions, annually. The nature of the services and products offered by the financial services industry (namely managing, controlling and possessing money and property belonging to others) means that it is vulnerable to abuse by money launderers.

REQUIREMENTS TO HELP DETER MONEY LAUNDERING

To help the government fight the funding of terrorism and money laundering, we are required to ask you to provide various identification documents or other information when opening or updating an account which may include but is not limited to your name, address, date of birth (for individuals), social security number and driver’s license or passport information.

CALIFORNIA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

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This Privacy Notice supplements Carty, Harding & Hearn, In.’s general Privacy Notice and applies solely to California residents. It reflects the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and other applicable California privacy laws.

Certain personal information collected in connection with financial products and services is subject to the Gramm-Leach-Bliley Act (GLBA) and may be exempt from portions of the CCPA/CPRA. Where California law applies, we honor applicable consumer rights.

CATEGORIES OF PERSONAL INFORMATION COLLECTED

Identifiers, customer records, protected classifications, commercial information, internet/electronic activity, geolocation (if collected), professional information, education information, audio/visual information, and sensitive personal information where necessary to provide services.

SENSITIVE PERSONAL INFORMATION

Sensitive personal information is used only for permitted business purposes such as identity verification, fraud prevention, regulatory compliance, account servicing and legal obligations. We do not use sensitive personal information to infer characteristics except as permitted by law.

SOURCES

Directly from consumers, broker-dealers, custodians, affiliates, service providers, public sources and website interactions.

BUSINESS PURPOSES

Account administration, transaction processing, fraud prevention, cybersecurity, regulatory compliance, audits, customer service, legal obligations and business operations.

RETENTION

Personal information is retained only for as long as reasonably necessary to fulfill disclosed purposes, comply with legal and regulatory obligations, resolve disputes and enforce agreements.

SHARING

We do not sell personal information. We disclose personal information to affiliates and service providers under contracts requiring confidentiality and limiting use to specified business purposes. We identify whether we share information for cross-context behavioral advertising, if applicable.

WEBSITE TECHNOLOGIES

Our website may use cookies, pixels, web beacons, SDKs, analytics tools, session replay technologies, fraud detection tools and similar technologies to operate, secure and improve the website.

WEBSITE COMMUNICATIONS

By using our website, you acknowledge that your interactions with the website may be monitored, recorded or analyzed through technologies used to operate, secure, troubleshoot, maintain and improve our services, consistent with applicable law.

CALL RECORDING

Telephone calls may be monitored or recorded where permitted by law for quality assurance, training, fraud prevention and regulatory compliance.

COOKIES

Users may manage cookie preferences where available. Essential cookies may remain enabled to support website functionality and security.

CALIFORNIA RIGHTS

California residents may request access, correction, deletion, portability, limitation of sensitive personal information (where applicable), and information regarding categories, purposes, recipients, sale or sharing of personal information. We will not discriminate against individuals exercising these rights.

HOW TO EXERCISE RIGHTS

Please refer to CHH’s Privacy notice and submit requests through the firm’s designated privacy request channels. We may verify identity before fulfilling requests.

CONTACT US

For questions regarding this notice or California privacy rights, contact the firm using the contact information provided in the general Privacy Notice or on the firm’s website.