Who we are
To Whom This Policy Applies
The policies and procedures described in this notice apply to individuals who inquire about and/or obtain products or services from The Hooker & Holcombe Companies for personal, family or household purposes. This includes individuals who use the features of our Defined Benefit or Defined Contribution webpages to view information about their retirement plans. The term "you" will be used throughout to refer to such individuals. This policy does not apply to institutional or commercial entities.
Information we collect, and how we use it
We collect nonpublic personal information about you (collectively referred to herein as "Collected Information") from the following sources:
- information we receive from you or your authorized representative, whether in writing, in person, by phone, electronically, via the Internet or other means, including, for example, information you provide through our website, on applications or other forms;
- information we receive about you from your plan sponsor; and
- information about your transactions with us, our affiliates or others.
We also gather information about pages you visit on our website and the duration of your visit. We use this information solely within our organization for the purpose of improving and managing our website. In order, for example, to determine the level of interest in information available on our website and to help us design or improve our products and services, we may use standard software to collect information about visitors to our website and use such information to create summary statistics. This information is maintained only in aggregated form and cannot be used to identify you.
Sharing of Nonpublic Personal Information
1. We do not sell your nonpublic personal information to anyone.
2. We do not disclose nonpublic personal information about you to any nonaffiliated parties, except as authorized by you or permitted by law. Our communication with affiliated parties may include, without limitation, (a) providing information to third parties that perform support services on our behalf or assist us in providing you with products and services that you request; (b) exchanging information with your plan sponsor to enable us to provide you with products or services that you request or otherwise service the plan in which you participate; and (c) sharing information within the Hooker & Holcombe Companies.
Protecting the Confidentiality and Security of Information
We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards to guard your nonpublic personal information.
For example, on our website we employ the following security-related techniques:
- User authentication procedures;
- Secure Socket Layer (SSL) 128-bit encrypted software, which requires the use of browsers with 128-bit encryption. Links are provided to the Netscape and Microsoft web sites, from which you can obtain free browser upgrades. We note, however, that our email services are NOT encrypted and, accordingly, ask that you refrain from sending personal nonpublic information to us via email unless you do so through a secure channel.
- Online access to an account will be disabled after three unsuccessful login attempts. A plan participant must contact his or her Human Resources department to get his or her account reactivated.
- Accounts will be automatically logged off if there is no keyboard activity for 20 minutes. To reestablish connection, a user must log on again.
In order to help maintain your nonpublic personal information in confidence, we ask that you (a) keep your username and password private and not share them with any third party; and (b) do not include personal information in email that you send to us unless you do so through a secure channel, since our email services are not encrypted.
Our website contains links to websites maintained and controlled by third parties. Please be aware that The Hooker & Holcombe Companies are not responsible for the privacy or security practices of third parties. We encourage you to be aware when you leave our website and to read the privacy and security statements of each and every website that you visit. This Privacy Statement applies solely to the practices of The Hooker & Holcombe Companies.
Please contact your plan sponsor's Human Resources department to report any inaccurate or missing data on your account. We can accept only those corrections and additions that are submitted to us from the plan sponsor.
Also, if you are concerned about on-line access to your information, you may have online access to your account terminated at any time. Please contact your plan sponsor's Human Resources department to have such access terminated.
Like most industries today, the financial services industry is rapidly being shaped by technology, which is literally changing the way we do business. To be successful in this environment, we must continue to ensure that our customers are confident that we will manage their financial affairs expertly and confidentially.
Hooker & Holcombe Investment Advisors, Inc. (hereafter known as “HHIA”) respects the privacy and confidentiality of all client information. The SEC’s (Securities Exchange Commission) privacy rule, Regulation S-P, requires investment advisers to issue initial and annual privacy notices to all clients. Regulation S-P places an affirmative obligation on advisers to ensure the security and confidentiality of your nonpublic personal information, which is defined as personally identifiable financial information obtained in any of the following ways:
- Information supplied by client
- Information resulting from transactions
- Information obtained in providing products or services
HHIA collects nonpublic personal information in the following ways:
- Information we receive from you on applications for your plan such as Employer Identification Number, Tax Identification Number, or Social Security Number.
- Information about transactions on behalf of your retirement plan(s) with custodian banks, brokers, mutual fund companies and third party administrators which include account balances, confirmation of transactions and fees paid to certain service providers (if applicable).
- Information about participant retirement plan payments such as name, social security number, address, date of birth, and payment amount (if applicable).
- Information provided by other service providers for your plan which may include, employee salaries, date of birth, estimated retirement dates, and estimated future benefit payments (if applicable).
HHIA does not disclose nonpublic personal information to non-affiliated third parties except as permitted by you or required by law. HHIA may disclose nonpublic personal information to its affiliated companies, Hooker & Holcombe, Inc., and Hooker & Holcombe Retirement Services, Inc., and to other third party administrators involved with administration of the account (e.g. plan custodian or trustee) to the extent it is necessary to conduct business and provide services on behalf of your retirement plan(s).
We want to assure all of our clients that whenever information is used, it is done with discretion. Access to information about your plan is restricted to only those employees who need to know such information to provide our services. HHIA maintains physical, electronic and procedural safeguards to ensure the security of your nonpublic personal information which include, for example, locking client file storage, restricted access to LAN based client files, and document shredding policy.
In the course of bidding on new business, HHIA is sometimes asked to provide a sample listing of current clients. In such situations HHIA will typically provide only the name of the business entity or town sponsoring the plan along with the approximate account size. Upon request from a client, HHIA will not include their information in such listings.