SW Private Wealth, LLC
Maintaining the trust and confidence of our clients is a high priority. That is why we want you to understand how we protect your privacy when we collect and use information about you, and the steps that we take to safeguard that information. This notice is provided to you on behalf of SW Private Wealth, LLC (“SWPW”).
Information We Collect: In connection with providing investment products, financial advice, or other services, we obtain non-public personal information about you, including:
- Information we receive from you on account applications, such as your address, date of birth, Social Security Number, occupation, financial goals, assets and income;
- Information about your transactions with us, our affiliates, or others; and
- Information about your visit to our website. We store that information in web server logs, which are records of the activities on our sites. The servers automatically capture and save the information electronically. The information we collect in web server logs helps us administer the site, analyze its usage, protect the website and its content from inappropriate use and improve the user’s experience.
Categories of Information We Disclose: We may only disclose information that we collect in accordance with this policy. SWPW does not sell customer lists and will not sell your name to telemarketers.
Categories of Parties to Whom We Disclose: We will not disclose information regarding you or your account at SWPW, except under the following circumstances:
- To entities that perform services for us or function on our behalf, including financial service providers, such as a clearing broker-dealer, investment company, or insurance company, other investment advisers;
- To comply with broker-dealer firms that have regulatory requirements to supervise certain representatives’ activities;
- To third parties who perform services or marketing, client resource management or other parties to help manage your account on our behalf;
- To your attorney, trustee or anyone else who represents you in a fiduciary capacity;
- To our attorneys, accountants or auditors; and
- To government entities or other third parties in response to subpoenas or other legal process as required by law or to comply with regulatory inquiries.
How We Use Information: Information may be used among companies that perform support services for us, such as data processors, client relationship management technology, technical systems consultants and programmers, or companies that help us market products and services to you for a number of purposes, such as:
- To protect your accounts/non-public information from unauthorized access or identity theft;
- To process your requests such as securities purchases and sales;
- To establish or maintain an account with an unaffiliated third party, such as a clearing broker-dealer providing services to you and/or SWPW;
- To service your accounts, such as by issuing checks and account statements;
- To comply with Federal, State, and Self-Regulatory Organization requirements; and
- To keep you informed about financial services of interest to you.
Regulation S-AM: Under Regulation S-AM, a registered investment adviser is prohibited from using eligibility information that it receives from an affiliate to make a marketing solicitation unless: (1) the potential marketing use of that information has been clearly, conspicuously and concisely disclosed to the consumer; (2) the consumer has been provided a reasonable opportunity and a simple method to opt out of receiving the marketing solicitations; and (3) the consumer has not opted out. SWPW does not receive information regarding marketing eligibility from affiliates to make solicitations.
Our Security Policy: We restrict access to nonpublic personal information about you to those individuals who need to know that information to provide products or services to you and perform their respective duties. We maintain physical, electronic, and procedural security measures to safeguard confidential client information.
Cyber Security: Internal policies and procedures are in place to address cyber security. A copy of this policy is available upon request.
Succession Planning: In the event that the owner(s) of SWPW retire, become incapacitated or perish unexpectedly, your information would be disclosed to an unaffiliated third party for the purposes of facilitating a business succession plan. A change in control of ownership of SWPW would require your consent, as dictated by your signed agreement with SWPW, in order to continue providing services to you.
Exceptions to Opt-In: The opt-in requirement also does not apply to disclosure of confidential information in the following circumstances:
- For resolving consumer or customer disputes or inquiries;
- To persons holding a legal or beneficial interest relating to the consumer or customer;
- To persons acting in a fiduciary or representative capacity on behalf of a consumer or customer;
- To provide information to agencies assessing your firm’s compliance with industry standards, and to your attorneys, accountants, and auditors;
- In connection with a proposed or an actual sale or merger of our firm;
- To respond to a regulator’s examination of our firm; and
- To comply with a civil, criminal, or regulatory investigation by federal, state, or local authorities.
Complaint Notification: Please direct complaints to: Annette Sun at SW Private Wealth, LLC, 75 Second Avenue, Suite 605, Needham MA 02494; (617) 866-0998.