Our Privacy Policy

At Convergent Capital Management, we know our clients expect and rely upon us to maintain the confidentiality and privacy of all the information about them in our possession and control. Maintaining the trust and confidence of our clients is our highest priority. We are, and always have been, committed to maintain the confidentiality of client information.

Our clients are those businesses and individuals to whom we provide our banking, trust, investment, and other financial services. We have adopted and published these privacy principles to guide our conduct when we collect, use, maintain or release client information and to assist our clients and others to better understand our privacy practices in general and as they apply to nonpublic personal information in particular.

First, we understand our moral, professional and legal obligations to our clients, former clients and other protected persons to maintain the privacy of all the confidential information about them in our possession and control. We will obey all applicable laws respecting the privacy of this information and will comply with the obligations of the law respecting nonpublic personal information provided to us. We regularly review and test our procedures and our technology to determine that this information is safeguarded to our satisfaction and as required by law.

Second, we collect, use and retain the information, including nonpublic personal information, about our clients and prospective clients that we believe is necessary for us to understand and better meet their financial needs and requests, to administer and maintain their accounts, to provide them with our products and services, to anticipate their future needs, to protect them and us from fraud or unauthorized transactions, and to meet legal requirements. We may share this information with our affiliates as permitted by law because some of our products and services are delivered through or in conjunction with our affiliates.

Third, we instruct our employees to limit the availability of all client information within our organization to those employees responsible for servicing the needs of the client and those employees who reasonably need such information to perform their duties and as required or permitted by law.

Fourth, we review our records and use our technology to determine that the client information we maintain is accurate, current and complete and is processed promptly. We require high standards of quality from the consumer reporting agencies and others who provide us with information about clients and prospective clients. We will respond quickly to a request to correct inaccurate information.

Fifth, we do provide client information, including nonpublic personal information, to our vendors and other outside service providers whom we use when appropriate and necessary to perform and enhance our client services. When we provide client information to anyone outside our organization we only do so as required or permitted by law. We require all of our vendors and service providers, who receive client information from us, to agree to maintain the information in confidence, to limit the use and dissemination of the information to the purpose for which it is provided and to abide by the law. We monitor or otherwise determine that each outside vendor and service provider receiving nonpublic personal information from us complies with our confidentiality requirements. To the extent permitted by law we undertake to advise a client of any government or other legal process served on us requiring disclosure of information about that client.

Sixth, except as stated above, we limit our disclosure of nonpublic personal information to third parties to the following circumstances:

1. When requested to do so by the client;
2. When necessary, in our opinion, to effect, administer, or enforce a client initiated transaction;
3. When made in accordance with standard banking industry practice to a reputable consumer reporting agency;
4. When required or permitted to do so by law or regulation, including authorized requests from government agencies and if we are the victim of fraud or otherwise suffer loss caused by the unlawful act of the client.

Seventh, we maintain security standards and procedures to respond to the risk of unauthorized access to client information.

Eighth, we educate all our employees about these privacy principles and their obligations to maintain confidentiality and privacy of client information as described in this Statement and our Code of Conduct and we take appropriate disciplinary measures to enforce these obligations.

We reserve the right to alter or amend this Statement and any of the policies or procedures described above at any time. Terms used in this Statement have the meaning given in Title V - "Privacy" of the Gramm-Leach-Bliley Act (Public Law 106-102, codified at 15 U.S.C. 6801 et seq.) or the regulations prescribed under that Act.