At Patton Albertson & Miller, we respect the personal and financial privacy of our clients. We recognize they have entrusted us with private and sensitive personal financial information. We also recognize the importance of ensuring that all of our employees and officers understand our policy regarding the treatment of our clients’ personal information.
The nature of our business requires that we collect personal financial information about our clients. Typically the collection of that information is from the following sources:
Information our clients provide to us in investment advisory agreements, brokerage account applications, and other documents completed in connection with the opening and maintenance of their accounts; and
Information our clients provide us orally; and
Information we receive from third parties, such as brokerage firms, about client transactions with us or with others.
We do not disclose any nonpublic personal financial information about our clients to anyone, except in the following circumstances:
When required in order to execute transactions for their account or otherwise provide services they have requested; or
When required to protect the confidentiality or security of the financial institution’s records against fraud and for institutional risk control purposes; or
When they have specifically authorized us to do so in writing; or
When required to provide information to the firm’s attorneys, accountants and auditors or others determining compliance with industry standards; or
When permitted or required by law.
We do not share non-public personal information with our affiliates. However, we share your non-public personal information with a non-affiliate for the purpose of aggregating it and providing summary information based on this data to our (non-controlling interest) parent company Focus Financial Partners, LLC. PAM Group, LLC (“PAM Group”) is a wholly owned subsidiary of Focus Financial Partners, LLC, a Delaware limited liability company. PAM Partners, LLC has full discretion and control in all matters related to management and operations of PAM Group.
Within our firm, we restrict access to clients’ personal financial information to the employees who need to know that information. To ensure security and confidentiality, we maintain physical, electronic, and procedural safeguards to protect the privacy of our clients.