Protecting your privacy is important to The Sanibel Captiva Trust Company and our employees. We want you to understand what information we collect and how we use it.
In order to provide our clients with a broad range of financial services as effectively and conveniently as possible, we use technology to manage and maintain customer information. The responsible use of client information enables us to understand your financial needs, improve products and services, comply with laws and regulations, and provide enhanced customer service. The following policy serves as a standard for all The Sanibel Captiva Trust Company employees for collection, use, retention, and security of nonpublic personal information.
What Information We Collect
We may collect “nonpublic personal information” about you from the following sources:
“Nonpublic personal information” is nonpublic information about you that we obtain in connection with providing a financial service to you. For example, nonpublic personal information includes information regarding your current assets, current estate plan, and beneficiary designations.
What Information We Disclose
We are permitted under law to disclose nonpublic personal information about you to third parties in certain circumstances. For example, as your fiduciary, we may disclose nonpublic personal information about you to our portfolio managers selected for your account. Such disclosure would be to ensure that the manager fully understands the scope and objective of your account. We may have to disclose information to government entities in response to subpoenas. However, we do not disclose any nonpublic information about you to anyone, except as permitted by law. If you decide to close your account(s) or become an inactive customer, we will continue to adhere to the privacy policies and practices described in this policy.
Our Security Procedures
We also take steps to safeguard customer information. We restrict access to your personal and account information to those employees who need to know that information to provide services to you. We maintain physical, electronic, and procedural safeguards to guard your nonpublic personal information. We also comply with Florida law regarding the retention of corporate records.
Code of Conduct
We have adopted a Privacy Policy Code of Ethics to ensure that all employees and directors are aware of their responsibility to protect client information. Each of the employees and directors of the Sanibel Captiva Trust Company is required to sign this Code of Ethics. The Code of Conduct also embodies principles of behavior such as respect for peers and the spirit of teamwork at all times.
Opt-Out Provision
Federal law does not require us to provide an Opt-Out provision because we do not disclose client information to third party vendors for marketing purposes. The Sanibel Captiva Trust Company is an exception to the law’s Opt-Out provision because we only disclose nonpublic personal information in the following circumstances: in connection with certain processing and servicing transactions; with the consent, or at the direction, of a client; to protect against potential fraud or unauthorized transactions; or to respond to judicial process.
The Sanibel/Captiva Trust Company considers privacy a fundamental right of clients and takes seriously the obligation to safeguard client information. For questions regarding this policy, please contact our Chairman, S. Albert D. Hanser.
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