Select Portfolio Management, Inc. - Select Money Management, Inc. - Securities Equity Group - SPM Insurance Services, Inc.

Privacy Policy - Notice Regarding Privacy of Customer Information

This notice is provided to you on behalf of Select Portfolio Management, Inc., Select Money Management, Inc., Securities Equity Group, and SPM Insurance Services, Inc. (collectively referred to in this notice as “we,” “us,” “our,” or “Affiliated Companies”). Protecting our customers’ privacy is of paramount importance. We recognize that an individual’s financial matters are private and sensitive in nature, and we have adopted policies that assist us in protecting your privacy and, at the same time, help us to provide you with a broad range of high-quality financial products and services.

This Privacy Policy will explain the types of information we collect about you, how we use and share that information, and how you can instruct us to limit certain types of information sharing. Information we obtain from all customers and former customers is treated in the same manner.

How We Protect Your Information

We protect your data and safeguard it from those not authorized to see it by adopting internal policies and procedures. Under no circumstances will we sell confidential customer information to anyone.

What Information We Collect About You

We collect confidential customer information from you in a number of ways for the following purposes:
- We collect information from you when you open an account or enroll in one of our services. The information we collect may include, but is not limited to: your name, address, phone number, email address, social security number and date of birth, as well as details about your investments and investment experience.
- Once you have opened an account with us, we collect and maintain confidential customer information about your account activity, including your transactions, balances, positions, and history. This information allows us to provide the services you have requested.
- We may collect information about you from information services and consumer reporting agencies to verify your identity, employment, or creditworthiness, or to better understand your financial needs.
- The law permits us to share information about our current and former customers with government agencies or authorized third-parties under certain circumstances. For example, we may be required to share such information in response to subpoenas or to comply with certain laws.

How We Share Information About You With Affiliated Companies

Founded in 1993, Select Portfolio Management, Inc. (“SPM”) is a federally regulated registered investment advisor affiliated via common ownership with Securities Equity Group (“SEG”), an independent broker-dealer, member of FINRA and SIPC, Select Money Management, Inc. (“SMM”), a federally regulated registered investment advisor, and with SPM Insurance Services, Inc., an independent wholesale insurance agency. We share information we collect about you among our Affiliated Companies to:
- help provide you with better service or perform services on your behalf;
- respond to communications from you or as you authorize or request;
- make it more convenient for you to open a new account; and
- allow an Affiliated Company to provide you with information about their products and services that we believe may benefit or interest you.

You may instruct us not to share information about you with our Affiliated Companies for certain purposes, as explained under "How to Limit the Sharing of Information about You."

How We Share Information About You With Non-Affiliated Companies

We provide access to information about you to outside companies and other third-parties in certain limited circumstances, including:
- to help us process transactions for your account;
- when we use another company to provide services for us, such as printing and mailing your account statements;
- when we believe that disclosure is required or permitted under law. For example, we may be required to disclose personal information to cooperate with regulatory or law enforcement authorities, to report your tax-related information to federal and state governments, to resolve consumer disputes, to perform credit/authentication checks, or for risk control.

If your SPM/SMM Wealth Manager or SEG Registered Representative leaves us to join another firm, they are permitted to retain copies of your information to facilitate the transfer of your account to a new broker-dealer or investment advisor in order to serve you at their new firm. Their continuing use of your information will be subject to the new firm’s privacy policy. You are not obligated to transfer your account if your Wealth Manager/Registered Representative leaves us, and you may instruct us not to allow the sharing of information as explained below under "How to Limit the Sharing of Information about You."

How To Limit The Sharing Of Information About You

If you prefer, you may choose to limit the information we share about you with our Affiliated and Non-Affiliated Companies. Specifically, you may instruct us:
- not to allow our Affiliated Companies to market their financial products or services to you;
- not to share confidential customer information about you with a Non-Affiliated company for joint marketing purposes; and/or
- not to allow your Representative to take your information to facilitate the transfer of your account(s) should they leave any of our Affiliated Companies.

You may exercise your choice by writing us at Select Portfolio Management, Inc., Attn: Compliance Department, 120 Vantis Drive – Suite 440, Aliso Viejo, CA 92656. Your choice will be applied to you as an individual and will automatically be extended to all of your accounts with any of our Affiliated Companies. You may make your privacy choice at any time and it will remain in effect until you change it in writing.

Safeguarding Your Information, Maintaining Your Trust

We take precautions to ensure the information we collect about you is protected and is accessed only by authorized individuals or organizations. Our employees are trained about privacy and are required to safeguard confidential customer information. We maintain physical, electronic, and procedural safeguards to protect confidential customer information.

Contact Us With Any Questions

If you have any questions or concerns, or if you identify any information that you believe is no longer accurate, you may contact your Wealth Manager or Registered Representative or write
 
Select Portfolio Management, Inc.
Attn: Compliance Department
120 Vantis Drive. – Suite 440
Aliso Viejo, CA 92656

Thank you for your business and allowing us to service your needs.

Our Business Continuity Plan 

Select Portfolio Management has developed a Business Continuity Plan regarding how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind,

We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm's books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Our clearing firm, National Financial Services, LLC, backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, our clearing firm has advised us that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within the same day of the occurrence. Your orders and requests for funds and securities could be delayed during this period. CLICK HERE for a PDF version of the NFS Business Continuity Plan.

Varying Disruptions 

Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe.

In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within the same business day of the occurrence. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area and recover and resume business within the same business day of the occurrence. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through the website of our affiliate Select Portfolio Management, Inc. (www.selectportfolio.com) as to how to contact us or obtain information regarding your investments. If the significant business disruption is so severe that it prevents us from remaining in business, we assure our customers prompt access to their funds and securities.

General Website Disclosures

The information presented on the SELECTPORTFOLIO.COM website is intended for informational use only and is not a substitute for investment, legal, tax, or insurance advice. State, national and international laws vary, as do individual circumstances; so always consult a qualified investment advisor, attorney, CPA, or insurance agent on all investment, legal, tax, or insurance matters. The effectiveness of any of the strategies described will depend on your individual situation and on a number of other factors (e.g. time horizon, risk tolerance, etc.)

There is no guarantee that any forecasts or opinions in any materials presented on theis website will be realized. Information should not be construed as investment advice. Any materials on this SELECTPORTFOLIO.COM website do not constitute the rendering of investment, legal, tax or insurance advice or services. They are intended for informational use only and is not a substitute for investment, legal, tax, and insurance advice.

State, national and international laws vary, as do individual circumstances; so always consult a qualified investment advisor, attorney, CPA, or insurance agent on all investment, legal, tax, or insurance matters. The effectiveness of any of the strategies described will depend on your individual situation and on a number of other factors. After reviewing your personal situation, we may recommend that you not use any strategy in this document but instead consider other strategies available through our practice. As with any investment strategy, there is potential for profit as well as the possibility of loss. Asset allocation does not ensure a profit or guarantee against a loss. Select Portfolio Management, Inc., Select Money Management, Inc., and all affiliated companies do not guarantee any minimum level of investment performance or the success of any portfolio or investment strategy.

All investments involve risk and investment recommendations will not always be profitable. Past performance is no guarantee of future results and current performance may be higher or lower than the performance shown. The investment return and principal value of an investment will fluctuate so that an investor's shares, when redeemed, may be worth more or less than their original cost. Please contact your advisor for additional information. Further information is available in the SPM - Firm Brochure, the SMM - Firm Brochure, and the SMM – Wrap Fee Program Brochure available on the footer of this website.

Website Cookies

Cookies are small bits of data that are deposited on a user's hard drive. The SELECTPORTFOLIO.COM website can utilize cookies and IP addresses for certain form and administration functions. Cookies simply permit the SELECTPORTFOLIO.COM website to be tailored to your needs and permit users to store their password and other user information without having to constantly re-enter this data. Most browsers permit users to decline to accept cookies, although the default setting is typically to accept them. You may choose to decline the cookies, but certain functions of the website may not be accessible to you.

Website Use of Information

SELECTPORTFOLIO.COM does not sell personally identifiable information, such as your name or email address to advertisers. However, non-personal "aggregated data" can be used to enhance the operation of our website.

SELECTPORTFOLIO.COM may also disclose personally identifiable information in order to respond to a subpoena, court order or other such requestor in response to a law enforcement agency's request.

Children are not encouraged or permitted to use the SELECTPORTFOLIO.COM website and as such, SELECTPORTFOLIO.COM does not knowingly collect personal information from children under the age of 13 from this website.

Third-Party Websites

SELECTPORTFOLIO.COM is not responsible for the privacy policies of websites to which it links. If you provide any information to such third-parties, different rules regarding the collection and use of your personal information may apply. We strongly suggest you review such third-party's privacy policies before providing any data to them. We do outsource some functions of the website for collection of payments, forms maintenance and content management, different rules regarding the collection and use of your personal information may apply with these service providers.

SEG (SEC Rule 606)

The Securities and Exchange Commission (SEC) adopted Rule 606 of Regulation NMS that requires broker-dealers, such as Securities Equity Group, to disclose information on order routing practices.

As an introducing broker-dealer, Securities Equity Group (“SEG”) exclusively routes all orders in Rule 606 reportable securities to its clearing broker, National Financial Services, LLC (“NFS”) for order routing. NFS presents this through quarterly reports, broken out by month, that illustrate an overview of order routing practices and the relationship between certain venues where orders are routed.

NFS may not be the ultimate execution venue for such orders, and these orders may be further routed to other execution venues. NFS is required to seek best execution for these orders. NFS receives renumeration (i.e. payment for order flow) for directing orders to particular broker-dealers or market centers for execution. SEG does NOT share in such payments. SEG does NOT direct, select or control the execution venues to which NFS routes Rule 606 reportable securities for execution. SEG performs regular and rigorous review of the execution quality for orders routed to NFS.

Since SEG adopts its clearing broker, NFS’s Rule 606(a) reports by reference, PLEASE CLICK HERE to view the most recent quarterly reports compiled by NFS.

Website Security

SELECTPORTFOLIO.COM takes appropriate steps to ensure data privacy and security in regard to the SELECTPORTFOLIO.COM website. SELECTPORTFOLIO.COM cannot guarantee the security of any information that is disclosed online.

Updates to Privacy Policy & Disclaimers

SELECTPORTFOLIO.COM reserves the right to modify this privacy policy at any time. Modifications become effective on the day they are posted. Frequently review the privacy policy for any modifications if this is important to you.

For More Information

If you have any questions or concerns, or if you identify any information that you believe is no longer accurate, please contact your SPM/SMM Investment Advisor Representative, SEG Registered Representative, SPM Financial Planner, or SPMI Insurance Agent.