For purposes of this policy, the terms "Consumer", "Client" and "Confidential Information" have the following definitions:
A. "Consumer" is not necessarily a client but may be anyone who obtains financial products or services from Sequoia used primarily for personal, family or household purposes. Examples of consumer relationships include: (1) a prospect with whom Sequoia is actively pursuing an investment relationship; or (2) a prospect who provides Sequoia with nonpublic information (such as net worth information or potential portfolio size) after attending a seminar or community event or listening to a radio talk show at which an employee of Sequoia is a featured speaker.
B. "Client" means (1) an individual with a specific and continuous relationship with Sequoia who obtains or has obtained a financial product or service from Sequoia used primarily for personal, family or household purposes; or (2) that individual’s designated representative.
C. "Confidential Information" is personally identifiable private information (information not available from public sources such as the phone book or a website) about the client or consumer, including information regarding name and address, age, social security number, assets, income, net-worth, account balance, account number, bank account information, beneficiary information and investment activity (such as purchase and redemption history).
Sequoia collects nonpublic information about clients and consumers. Sequoia shall not share nonpublic personal information about clients or consumers with third parties not affiliated with Sequoia, except as noted below.
Specifically, Sequoia may share nonpublic personal information as necessary:
1. To complete transactions or account changes as directed by the client;
2. To maintain or service a client’s account;
3. If requested or authorized to do so by a client;
4. With contracted service providers providing administrative functions for Sequoia; or
5. If Sequoia is required or permitted by law or regulatory authorities with jurisdiction over the firm to do so.
Safeguarding of Client Records and Information
Sequoia will maintain administrative, technical and physical safeguards reasonably designed to ensure the security and confidentiality of client records and information.
To protect this information, Sequoia will:
B. Refrain from providing client information over the telephone or in response to an e-mail message unless the employee has identified the other person as the client, a fiduciary representative of the client, an authorized agent of the client or a party that needs the information to complete a transaction for the client (such as broker-dealers, custodians or administrative service providers).
C. Limit access to confidential information about clients to those employees who need to know such information.
D. Maintain appropriate security measures for computer and information systems, including the use of passwords and firewalls.
E. Use locks and other appropriate physical security measures to safeguard client information stored in paper format. For example, employees are expected to secure client information within locked cabinets during non-business hours.
F. Dispose of client information stored in electronic or paper form in such a manner (e.g., through the use of a shredder) to reasonably ensure such information is protected from unauthorized access.
G. Engage a third party service provider only after Sequoia has entered into a contractual agreement that prohibits the service provider from disclosing or using confidential personal information except as necessary to carry out its assigned responsibilities.