Effective: March 1, 2012
Our Commitment to You
Hogan Investment Counsel, LLC ("Hogan") is committed to safeguarding the use of your personal information that we have as your Investment Advisor. Hogan (referred to as "we", "our" and "us" throughout this notice) protects the security and confidentiality of the personal information we have and make efforts to ensure that such information is used for proper business purposes in connection with the management or servicing of your account. Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything we can to maintain that trust.
We do not sell your non-public personal information to anyone. Nor does Hogan provide such information to others except for discrete and proper business purposes in connection with the servicing and management of your account as discussed below.
The Information We Collect About You
You typically provide personal information when you complete the paperwork required to become our Client. This information may include your:
- Name and address
- E-mail address
- Phone number
- Account balance
- Social security or taxpayer identification number
- Investment activity
- Accounts at other institutions
In addition, we may collect non-public information about you from the following sources:
Information we receive on Brokerage Agreements, Managed Account Agreements and other Subscription and Account Opening Documents; Information we receive in the course of establishing a customer relationship including, but not limited to, applications, forms, and questionnaires; Information about your transactions with us or others
Information About You That Hogan Shares
Hogan works to provide products and services that benefit our customers. We may share non-public personal information with non-affiliated third parties (such as brokers and custodians) as necessary for us to provide agreed services and products to you consistent with applicable law. We may also disclose non-public personal information to other financial institutions with whom we have joint business arrangements for proper business purposes in connection with the management or servicing of your account. In addition, your non-public personal information may also be disclosed to you, persons we believe to be your authorized agent or representative, regulators in order to satisfy Hogan regulatory obligations, and is otherwise required or permitted by law.
Lastly, we may disclose your non-public personal information to companies we hire to help administrate our business. Companies we hire to provide services of this kind are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to the performance of the specific service we have requested.To repeat, we do not sell your non-public personal information to anyone.
Information About Former Clients
Hogan does not disclose, and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our clients.
Confidentiality and Security
Our employees are advised about the firm's need to respect the confidentiality of our customers' non-public personal information. Additionally, we maintain physical, procedural and electronic safeguards in an effort to protect the information from access by unauthorized parties.
We'll Keep You Informed