Privacy Policy
Last Modified: 10/18/2024
The privacy policy statement is given to clients at the initial signing of the client contract and mailed or emailed with client consent once annually if the policy is updated. The CCO will document the date the privacy policy was delivered to each client for each year if an annual delivery is required. TFA collects non-public personal information about clients from the following sources:
- Information it receives from them on applications or other forms;
- Information about their transactions with TFA or others; and
- Information it receives from a consumer reporting agency.
TFA does not disclose any non-public personal information about clients to anyone, except as permitted by law. If a client decides to close his or her account(s) or becomes an inactive customer, TFA will adhere to the privacy policies and practices as described in this notice.
TFA may use the information provided to communicate via phone, text (SMS), and email. You have the right to update your information or request communication by a preferred method. You can opt-out at any time to text (SMS) messages by replying STOP or contacting us at info@teamworkfinancial.com
TFA restricts access to clients’ personal and account information to those employees who need to know that information to provide products or services to its clients. TFA maintains physical, electronic, and procedural safeguards to guard clients’ non-public personal information.
In addition to TFA’s listed access persons, any IT persons or other technical consultants employed at the firm may also have access to non-public client information at any time. An on-site or off-site server that stores client information, third-party software that generates statements or performance reports, or third-party client portals designed to store client files all hold the potential for a breach of non-public client information.
To mitigate a possible breach of the private information, TFA uses encryption software on all computers and carefully evaluates any third-party providers, employees, and consultants with regard to their security protocols, privacy policies, and/or security and privacy training.
The system is tested and monitored at least monthly.
The test conducted by the CCO will include the following activities:
- Attempt to access a random sample of firm devices to ensure that proper passwords are in place to prevent access;
- Attempt to access users’ accounts with the proper password to ensure that two-factor authentication prevents system access; and
- Attempt to restore a sample of files and records to ensure that the restoration process is sufficient and properly configured.
The results from the annual test will be documented and utilized as an opportunity to update the Information Security Policy.
Staff Training
On an annual basis, TFA will conduct a firm-wide training session to ensure that staff members are properly trained and equipped to implement the above policies. New staff members will receive training, led by Monica Wiggins, Office Manager, within 1 month of their initial hire date.
TFA uses various methods to store and archive client files and other information. Third party services or contractors used have been made aware of the importance TFA places on both firm and client information security. In addition to electronic and personnel measures TFA has implemented reasonable physical security measures at its home office location.
TFA will retain records for at least 5 years after the year in which the record was produced, or as otherwise required by law. With respect to disposal of non-public personal information, TFA will take reasonable measures to protect against unauthorized access to or use of such information in connection with its disposal.
SMS
No mobile or messaging consent information will be shared with third parties/affiliates for marketing or promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
