Nonpublic Financial Information Policies – Regulation S-P
Current as of January 29, 2018
Policy to Safeguard Customer Records and Information
Our procedures are reasonably designed to:
- Insure the security and confidentiality of customer records and information;
- Protect against any anticipated threats or hazards to the security or integrity of customer records and information; and
- Protect against unauthorized access to or use of customer records or information that could result in substantial harm or inconvenience to any customer.
We restrict access to nonpublic personal information about customers to those employees who need to know that information to provide products or services to customers or as is otherwise permitted or required by law.
We electronically maintain and/or transmit to affiliated entities or service providers, nonpublic personal information on or over what are represented to us as and what we believe to be secure protocols. Access to this information is restricted to individuals who need to know that information to provide products or services customers expect to receive from us or as is otherwise permitted or required by law.
We maintain both electronic storage media and physical documents containing customer nonpublic personal information by means which we believe are secure and private. We transmit such information to affiliated entities or service providers (a) electronically, by means which we believe are secure, and (b) physically, by the United States Postal Service or independent overnight courier.
We require that customer records and information be properly disposed of to protect against unauthorized access and use of consumer records and information.
Capital Research & Consulting LLC provides advisory and consulting services by means of its own internal operation. Capital Research & Consulting LLC receives and maintains information about you that is related to and necessary for conducting investment advisory and consulting services for your plan.
WHERE DO WE OBTAIN THE INFORMATION. The information that we have comes directly from you. This includes such information as your name (or plan name), address and social security number or tax identification number that you provided on applications, agreements or other forms. In addition, we may maintain records of each of your transactions and holdings processed with regards to your plan.
TO WHOM DO WE DISCLOSE THE INFORMATION. We provide information about current or former clients from the sources described above to parties outside of this firm only as described below:
To other companies as necessary to process your business.
For example, we process your mutual fund and variable product transactions through product providers with whom we have dealer selling agreements. These parties must limit their use of the information to the purpose for which it was provided.
Where required by law or regulation.
Examples include responses to a subpoena, court order or regulatory demand.
As authorized by you.
You may direct us, for example, to send account statements or other account information to a third party.
As otherwise authorized or permitted by law.
For example, the law permits us to respond to a request for information about you from a consumer-reporting agency.
CONFIDENTIALITY AND SECURITY. We restrict access to information about you to those employees and authorized agents who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards to maintain the confidentiality of your information.
Website Visitors: How We Keep Your Personal Information Confidential
If you’re not a client, but have visited our website, the following may apply to you.
No sharing or selling of email or phone numbers.
Capital Research & Consulting LLC does not sell, rent, share, or otherwise give your personally identifiable information to third parties for marketing purposes.
Email policy. If you contact us, your email will be used to deliver emails requested and also to send periodic follow up emails. You may opt out of these lists at any time.
Use of website cookies. Capital Research & Consulting LLC uses session ID cookies and may also use persistent cookies. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive or device for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “Help” file. For more information on cookies, one informative link is at http://www.microsoft.com/info/cookies.mspx. We may set a persistent cookie to remember the affiliate from whom you found our website. If you reject cookies, you may still use our website. We do not track user activity after a user leaves our website. We may use beacons, web server logs, widgets, and other technologies. “Web beacons” or “clear pixels” are small graphic images on a webpage or in an email that can be used for such things as recording the pages and advertisements clicked on by users, or tracking the performance of email marketing campaigns. A “web server log” is a record of activity created by the computer or device that delivers the webpages you request to your browser. For example, a web server log may record the search term you entered or the link you clicked to bring you the webpage. The web server log also may record information about your browser, such as your IP address and the cookies set on your browser by the server. A “widget” is a small program or application that can be embedded in a web page. Widgets can provide real-time information, such as stock quotes or weather reports, or other functionality, such as an availability button, a buy now button, or a contact support button. Widgets are often provided by a third party, and may allow the third party to collect data about users viewing that page. We may also use social media features such as the Facebook Like button, a Twitter button, or other social media features. These features may collect your IP address and the page you are visiting on our website and may also set a cookie to enable the feature to function properly.
ADV Part II available upon request.