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J.E. Kelleher Privacy Policy and Disclosure

J.E. Kelleher Privacy Policy and Disclosure

 


The directors, management, and staff of J.E. Kelleher are concerned about and respect the privacy of our customers' financial information. We understand that our customers furnish private information to our companies in the course of daily business, and we are committed to treating such information responsibly. We know that our customers expect privacy and security for their personal and financial affairs.


We will take steps to safeguard private information that has been entrusted to us by our customers. When we do use information, it is to help serve you better. Your information helps us appreciate all the business you have with our companies and identify affordable products and services that might serve you better. The following privacy policy and disclosure outlines our practice regarding personally identifiable financial information (or "nonpublic personal information") for consumers, those consumers who become our customers, and our former customers. This disclosure is made on behalf of (but not limited to) J.E.Kelleher, Inc.

USE OF INFORMATION

We use personal information in ways that are compatible with the purposes for which we originally requested it. For example, we will use the information you give us to process your requests and transactions, to provide you with additional information about products and services or to evaluate your business needs. We collect and use personal information to administer our business and deliver quality service to you. This may include advising you about our products or services, those of our affiliates, those of our business partners and other opportunities that we believe may interest you.

CUSTOMER PRIVACY BILL OF RIGHTS

J.E. Kelleher Employees
At J.E. Kelleher, any employee access to customer information is authorized for business purposes only and is based on the sensitivity of the information and our employees' or agents' need to know. We remind employees regularly of their obligations for using customer information. Disregard of these obligations will result in disciplinary action, including termination in appropriate cases.

Information Collection
At J.E. Kelleher, we collect, retain, and use information about you for the purpose of serving your business needs and administering our account relationships. We collect information we receive from you on our registration form and other forms like surveys and questionnaires (for example, requests for information about products and services). We also collect (i) information about your transactions with our affiliates, others or us and (ii) information we receive from consumer reporting agencies.

INFORMATION SHARING

The foregoing information about both current and former customers may be shared with the following categories of J.E. Kelleher companies and unaffiliated third parties:

Sharing Within J.E. Kelleher's Family of Companies
To the extent permitted, this information may be shared among Surplus Asset Management's family of companies (for example, a bank, an insurance company, or a broker-dealer) in order that we can provide products and services appropriate to your needs and circumstances. (For more information about information sharing options, see the "Your Choices" section below.)

Sharing with J.E. Kelleher's Service Providers/Joint Marketers
We may use outside companies to perform services for us, to assist in marketing our own products and services or products or services we market jointly with other financial institutions, and to perform market research. In order to complete these tasks, we may provide our service providers with information we collect about you. We require our service providers to comply with our standards regarding security and confidentiality, and permit them to only use your information for purposes authorized by us.

J.E. Kelleher may also enter into joint marketing agreements with selected companies. We may disclose all of the information we collect, as described above, to these selected financial institutions in order to assist us in providing quality products and services to you.

We require these companies to keep your nonpublic personal information confidential, and permit them to only use your information for purposes authorized by us.

You should also be aware that there may be occasions where we are legally required to disclose information about you, such as in response to a subpoena, to prevent fraud, or to comply with a legally permitted inquiry by a governmental agency or federal regulator. We do not disclose any nonpublic personal information about you to any third parties, except as permitted by law.

Security Standards

We have established and continually maintain security standards and procedures to help us protect you from unauthorized access to confidential nonpublic personal information that J.E. Kelleher maintains about you, including through the Internet.

ACCURACY AND RIGHT TO CORRECT

Your Account Information
We continually strive to maintain complete and accurate information about you and your accounts. Should you ever believe that our records contain inaccurate or incomplete information about you, please notify us. We will investigate your concerns and correct any inaccuracies.

Information Reported to Consumer Reporting Agencies
Under the Fair Credit Reporting Act, you have the right to notify us if you believe we have reported inaccurate information about your account to any consumer-reporting agency. Such notices should be sent in writing and include your complete name, current address, social security number, telephone number, account number, type of account, specific item of dispute and the reason why you believe the information reported is in error. Send your notice to J.E.Kelleher, Inc., PO Box 217, Bristol, CT 06011. We will investigate your concerns and correct any inaccuracies and confirm our actions to you.

YOUR CHOICES

Information Shared Within J.E. Kelleher's Family of Companies
Responsible use of information benefits our customers both by protecting you and enabling us to provide more relevant and customized products and services to meet your business needs. At J.E. Kelleher, we share customer transaction and experience information within our family of companies through a central information system.

We are permitted to share other customer information within our family of companies. This can help us improve the type and selection of products and services we provide. If you do not want us to share this other information (except transaction and experience history) among Surplus Asset Management's family of companies, complete the form provided in this disclosure.

The registration and profile update forms allow for options to identify you as a participant in information sharing. We will process your request as soon as possible after we receive it.

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