March 1, 2022
At Sterneck Capital Management, we consider it a privilege to serve your financial needs and we value the trust
you have placed in us. As we serve your financial needs, we are committed to safeguarding your personal
We hold all personal information provided to us in the strictest confidence. These records include all personal
information that we collect from you in connection with the services provided by Sterneck Capital Management,
LLC. We do not disclose information to non-affiliated third parties, except as permitted by law, and do not
anticipate doing so in the future. If we were to anticipate a policy change, we would be prohibited under law from
making a change without advising you first.
We do share information with others who provide services for our clients* only if the information is required to
• We maintain a secure office and computer environment to ensure that your information is not placed
at unreasonable risk.
• We collect non-public personal information about you from information we receive from you or your
primary custodian. This information is typically relayed to us on applications or other forms that you have
• Certain non-affiliated third parties, such as auditors, may require access to your personal information.
We also require strict confidentiality in our agreements with them and expectthem to keep this
• We do not provide your personally identifiable information to mailing list vendors or solicitors for any
purpose. From time to time we may engage an independent third party to conduct anonymous client
surveys on our behalf, though we expect such firms to use information we provide for this sole purpose.
• We limit access to information only to those who have a business or professional reason for
knowing. 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
• 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