When we refer to the non-public financial and personal information of a client and a client’s family, we mean the following types of information contained in paper files, computer related systems and email systems:
*For purposes of this Policy, “client,” “you,” or “your” means the owner (single or joint) of the account at Market Street.
Because protecting your financial and other personal information is of the utmost importance to us, we take substantial steps to safeguard the confidentiality, integrity and security of your information both physically and electronically, including password protecting and otherwise locking our servers, computers, databases and other software and hardware containing client information.
Certain information, such as fiduciary information, is subject to more restrictive sharing limitations than other kinds of information.
We strive to keep your information accurate and up to date.
Further, all Market Street employees and third-party vendors with access to financial or personal information are required to enter into written confidentiality agreements. All Market Street employees are advised of their obligations relating to client privacy including proper maintenance and disposal of written documents and electronic data.
If unauthorized disclosure or access may have occurred, employees are expected to report such breach immediately.
Market Street will promptly investigate and redress any violation of this Policy.
WITH YOUR CONSENT
Other than as described in this Policy, we do not share your financial and personal information with anyone outside of Market Street unless needed to perform work for you that you have approved (such as legal or tax advisory services) and then only to the extent necessary to provide the services requested on your behalf.
WITH CERTAIN SERVICE PROVIDERS
From time to time, Market Street engages service providers to assist Market Street in its day to day business operations. During the course of such engagements, we may provide client financial and personal information to service providers who have a need to know such information to be able to perform certain services (such as financial auditing) or install certain products (such as accounting software). Even then, all service providers with access to such information are supervised and are required to enter into written confidentiality agreements that restrict their use or disclosure of such information.
IN A FORMAT THAT DOES NOT PERSONALLY IDENTIFY YOU
We may report your financial and other personal information in an aggregate or grouped form without identifying you personally, such as to the Market Street Board of Directors or to third parties. For example, we may report Market Street aggregate investment performance for business development purposes or for industry research purposes.
OTHERWISE AS PERMITTED BY LAW
We also may disclose your financial and other personal information when required by law, such as in the case of fraud prevention or investigation. As permitted by law and upon prior notice to you, we reserve the right to share information in the future.
Market Street is unique in that, as a family office, we may provide services not only to you as an individual client (the owner of the account) but also to your spouse, minor or adult children and to extended family members. These services may be provided to your family members either as clients themselves or as income beneficiaries or remainder beneficiaries of family trusts or of individual trusts you establish, borrowers on intra-family and/or trust loans, board members on family foundations, etc. This Policy applies whether or not a family relationship exists. No family member client is privileged to learn the financial and personal information of another adult family member unless the latter has first agreed to share such information or as applicable by virtue of a trust or other agreement.
If you would like to ensure that your financial information and personal information are shared with certain family members, please contact your Relationship Manager to discuss this arrangement further.
We also ask that our clients do their part to protect their own financial and other personal information against disclosure and unauthorized use. This includes but is not limited to taking the following precautions:
Policy approved: 4/21/2022