Everything we do to keep you safe.
Sterneck Capital Management, LLC (“Sterneck Capital”) recognizes and respects the privacy expectations of our clients.We provide this notice to you so that you are aware of the types of information we collect about our clients and the circumstances in which that information may be disclosed to third parties who are not affiliated with Sterneck Capital.
Collection of Client Information
We collect nonpublic personal information about our clients from the following sources:
• Account Applications, advisory agreements and other forms, which may include a client’s name, address, social security number, driver’s license and information about a customer’s investment goals and risk tolerance;
• Account History, including information about the transactions, cost basis and balances in a client’s account; and
• Correspondence, written, telephonic or electronic, between a client and Sterneck Capital or service providers to Sterneck Capital.
Among other sources, we may collect this information through Internet web sites.
Disclosure of Client Information
We may disclose all of the information described above to certain third parties who are not affiliated with the firm under one or more of the following circumstances;
• As Authorized – if you request or authorize disclosure of the information.
• As Required by Law – for example, to cooperate with regulators or law enforcement authorities.
• As otherwise Permitted by Law – for example, sharing information with companies that maintain, process or service customer accounts or financial products and services or effect, administer or enforce customer transactions is permitted. Among other activities, we may share information with broker-dealers in order to execute customer trades or with custodians that hold securities on behalf of customers. We believe that sharing of information for these purposes is essential to providing clients with necessary or useful services with respect to their accounts.
• Under Joint Agreements – we may also share information with companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements.
Security of Client Information
We require service providers to the firm:
• to maintain policies and procedures designed to assure only appropriate access to information about customers of the firm;
• to limit the use of information about the firm’s customers to the purposes for which the information was disclosed, or as otherwise permitted by law; and
• to maintain physical, electronic and procedural safeguards that comply with federal standards to guard non-public personal information about our customers.
We will adhere to the policies and practices described in this notice regardless of whether you are a current or former client of the firm.
If you have questions regarding these policies, please contact us by writing to Sterneck Capital Management, 4510 Belleview Ave., Suite 204, Kansas City MO. Attention: Mr. Regan Ervin, or by calling 816.531.2254.
For purposes of this notice, the terms “client” or “clients” include both (i) individuals who have a continuing account management or advisory relationships with the firm (e.g., by having an management contract with the firm) and (ii) individuals who provide nonpublic personal information to the firm, but who do not have a continuing relationship with the firm (e.g., an individual who provides such information in deciding whether to become a client, whether or not the individual establishes a continuing relationship with the firm).
Sterneck Capital has developed business continuity plans to address the possibility of a significant business disruption. Plans are reviewed, updated and exercised on a regular basis. Should an event occur that hinders our ability to conduct normal business operation, Sterneck Capital has secured remote locations to resume critical business operations within a reasonable period of time. Should business functions be interrupted by the loss of a primary business facility, associates and/or “work” would be relocated to an alternate site. In the event of a systems loss, applications would be redirected to our primary recovery location, which could be an alternate facility or a remote recovery service provider. The hierarchical structure of Sterneck Capital’s recovery plans includes the ability to address incidents that are facility, city, state or regional in nature.
Sterneck Capital Management, LLC is not engaged in the practice of law and does not provide legal advice. Always consult with an attorney regarding your specific legal situation.