Dear Client:
The CFTC has adopted its Financial Privacy rules
following enactment of the Commodity Futures Modernization
Act of 2000 (CFMA). It requires FCM's, IB's
and CTA's to comply with the Gramm-Leach-Bliley Act
(GLB).
DeSpenza Capital Management, LLC Privacy
Policy includes all Non Public Personal Information
(NPPI). NPPI includes all personally identifiable
information that is not publicly available:
A. Account numbers and access codes
B. Non-published telephone numbers
C. Information with regards to salary and
net worth
DeSpenza Capital Management, LLC does
reserve the right to share NPPI with its affiliates
(any company that controls, is controlled by or is
under common control with DeSpenza Capital Management,
LLC.) – DeSpenza Capital Management, LLC agrees not
to share NPPI with a non-affiliated third party (any
person except a DeSpenza Capital Management, LLC
affiliate or a person employed by DeSpenza Capital
Management, LLC, and a company that is not a DeSpenza
Capital Management, LLC affiliate).
All NPPI of former customers of DeSpenza Capital
Management, LLC will be treated in the same manner
as current customers.
The Policy of DeSpenza Capital Management,
LLC with regard to the security and confidentiality
of the NPPI is as follows:
A. All NPPI will be kept in the customer's
account folder and filed with access
by authorized personnel only.
B. No NPPI is ever given out over the telephone
or electronically to anyone
except an affiliate (see exceptions below).
C. Affiliates are also instructed to never
give out NPPI on a client (see
exceptions below).
Two (2) exceptions to the Privacy Policy:
1. As necessary to process or service a transaction
that the customer requested.
2. For specified reasons:
A. customer has consented to disclosure
B. to protect against unauthorized transactions
C when made to by our attorneys, accountants
and auditors, and to
governmental regulatory authorities as authorized
by law.
It is DeSpenza Capital Management, LLC policy to
never share any information with marketers or service
providers. Client information is considered
private and will be treated accordingly except for
the aforementioned exceptions.
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