Policy effective date: July 11,2016
Your Privacy Matters
Gate Key Financial’s number one priority is your trust. Your privacy is essential to earning and keeping that trust. This tenet drives all of the decisions we make, as well as how we gather, use and store any information we acquire from you.
Welcome to gatekeyfinancial.com This Site is owned and operated by Gate Key Financial. Protecting your privacy is important to us. We take precautions to ensure that your information is kept private and confidential. To assist us in providing you the quality services and products that you request or to help meet your needs, we gather, maintain, and use both public and nonpublic personal information about you. We are providing you with the following policies and practices with respect to sharing of customer information.
COMMITMENT TO YOUR PRIVACY
HOW WE GATHER INFORMATION
We collect your personal information in the process of establishing and administering your accounts.
- Application information. When you open an account with Gate Key Financial, you provide information to us on your account application. This information may include your name, address, phone number, email address, Social Security number, and information about your investment experience, objectives, current investments, and information we may obtain from third-parties.
- Transaction information. Any time you initiate a transaction in an account with us, we collect information about that transaction. We also keep information about your accounts with us, such as transaction history, current balances and current investments. These records also may include the application information listed above.
HOW WE USE AND SHARE INFORMATION
We share your personal information only for our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus – and it is limited to those parties who assist us in establishing and administering your account. We do not sell your personal information to anyone.
- Use of information. We use your personal information to establish and administer your accounts, to alert you to services we provide, and to fulfill our regulatory obligations.
- Sharing information for the purpose of providing service. We disclose your personal information to those parties who assist us in processing your transactions or otherwise providing service to your accounts. In order to improve the services we provide, we also may disclose personal information, such as transaction history and investment objectives, to Capital Wealth Management, LLC or Silver Oak Securities, Inc..
- Sharing information for legal purposes. In certain circumstances, we may share personal information as required or permitted by law. We may do so, for example, to cooperate with regulators or law enforcement authorities, to resolve consumer disputes, or for institutional risk control.
HOW WE PROTECT INFORMATION
Even when we share your personal information, we remain committed to maintaining your privacy. We take steps to protect confidentiality of personal information whenever possible.
- Contractual protections. We have contracts with all of our employees and with unaffiliated companies with whom we share personal information, prohibiting them from using such personal information for any purpose other than that for which it is disclosed, and further prohibiting them from disclosing it to any other parties.
- Sharing with affiliates. We do not share personal information with affiliates unless it is necessary to service your accounts or as permitted by law.
- Physical and procedural safeguards. We maintain physical, electronic, and procedural safeguards to protect the confidentiality of your personal information. We also restrict employee access to your personal information to those employees who need to know that information in the course of their job responsibilities.
We consider privacy, security, and service in our online operations to be just as critical as in the rest of our business. We therefore employ all of the safeguards described above, along with the following Internet-specific practices.
We use a variety of proven protections to maintain the security of your online session. For example, we make extensive use of firewall barriers, encryption techniques and authentication procedures. We may also use “cookies” and similar files that may be placed on your computer’s hard drive for security purposes, to facilitate site navigation, and to personalize your experience on our site.
When you visit our website, we may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on our website. This information may be used, for example, to alert you to software compatibility issues; or it may be analyzed to improve our web design and functionality.
When you visit password-protected areas of our website, we will require you to enter your individual login ID and password. In such cases, your browsing will no longer be anonymous to us. However, we will use your personal information only to provide you with account information or otherwise as listed above.
While we take active steps to protect all information we receive online, we cannot guarantee the security of any information you transmit to us via the Internet. Emails you send us are not necessarily secure when they are transmitted to us. Therefore, if your communication is very sensitive or includes highly confidential information such as a social security number or an account number, it may be prudent for you to use a method of transmission other than email or otherwise encrypt such information.
FORM ADV & BROKERCHECK
The Securities and Exchange Commission (the “SEC”) recently amended the content, delivery and filing requirements of Form ADV Parts 1 & 2. These documents describe the services, business practices and relationships of Gate Key Financial. Gate Key Financial has recently updated both Parts 1 and 2 of Form ADV. Part 2 is now available on the SEC’s website at www.adviserinfo.sec.gov along with Part 1, but if you would like to receive a free copy of either ADV Part 1 or Part 2 directly from Gate Key Financial, please call 919.590.2312.
The Financial Industry Regulatory Authority (“FINRA”) maintains a free hotline and online tool known as BrokerCheck to help investors research the professional backgrounds of current and former FINRA-registered brokerage firms and brokers. FINRA’s BrokerCheck hotline number is 1-800-289-9999; BrokerCheck can also be accessed at FINRA’s website, www.finra.org. If you would like to receive a free brochure that includes information describing BrokerCheck directly from Gate Key Financial, please call 919.590.2312.
UPDATE YOUR INFORMATION
Should you have significant life changes, such as a marriage, birth of a child, change of contact information, death of a spouse, divorce, or a significant change in your financial situation, please contact your advisor to determine if such changes will alter your investment objectives, risk tolerance, or investment horizon.
CODE OF ETHICS
Gate Key Financial maintains a Code of Ethics governing its relationship with investors. If you would like a free copy of our Code of Ethics or would like to discuss a complaint, please call 919.590.2312 and ask for the Compliance Department.
ANTI- MONEY LAUNDERING
While we take great care in attempting to know our investors’ individual investment goals and objectives today, the Act requires us to take additional steps to verify the identity of persons opening new accounts, including verifying the identity of prospective investors, consulting applicable government agency lists of known or suspected criminals, terrorists and terrorist organizations to determine if any of our prospective or current investors are on such list, and conducting, in certain circumstances, additional due diligence when accounts are opened, including requesting information about the source of funds deposited into such accounts.
Gate Key Financial intends to comply with this and all other requirements of law, and we thank you for your assistance in meeting our obligations.
BUSINESS CONTINUITY PLAN
Gate Key Financial has developed a Business Continuity Plan (the “Plan”) designed to prevent or mitigate potential business disruption. Since the timing and severity of events that can lead to business disruption are unpredictable, our Plan is comprehensive, continually evolving, and practiced on an ongoing basis.
Our Plan is designed to safeguard our employees and property, protect the firm’s books and records, allow our advisors and clients to transact business, and communicate effectively with all stakeholders. Our Plan is also designed to ensure business is not disrupted and to permit our firm to resume business as quickly as possible if there is a disruption.
Our Plan addresses data back-up and recovery, critical technology and communications systems, financial and operational assessments, alternative communications with advisors, clients, employees and regulators, alternate physical locations for employees, critical suppliers and contractors, regulatory reporting, and ensuring prompt access to information if there is a business disruption.
Gate Key Financial’s objective is to have critical functions operational within one hour. However, in severe or widespread situations, operations could be delayed for a longer period of time. In the event of a disruption, we will notify you through regular communications on our website gatekeyfinancial.com or via email, if appropriate.
If after a business disruption you cannot contact us at 919.590.2312, please contact your assigned investment advisor representative via email or visit gatekeyfinancial.com for information related to the business disruption including contact information as appropriate.
FOR MORE INFORMATION
If you have questions about our Plan, please contact Gate Key Financial’s Chief Compliance Officer at 919.590.2312.