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Privacy Lee Financial Corporation (LFC) recognizes its obligation to keep personal
and financial information about clients secure and confidential. This Privacy
Notice defines nonpublic personal information and its sources and describes
who has access to it once we receive it. It also informs clients of the measures
we take to protect the confidentiality and security of the information.
Sources of Information
LFC collects and uses various types of information about our clients to better
understand their needs and objectives. Most of the nonpublic personal information
LFC collects about our clients comes directly from the client through the following
sources:
- Information received from clients for planning purposes, primarily demographic
and financial in nature.
- Information about clients' investment holdings and the transactions that
LFC executes on their behalf.
- Information received from clients on applications or other forms.
- Information about clients' transactions with LFC, our affiliates, or others.
LFC has adopted policies and procedures reasonably designed to: (a) ensure
the confidentiality of client records and information; (b) protect against any
anticipated threats or hazards to the security of client records and information;
and (c) protect against unauthorized access or use of client records or information
that could result in substantial harm or inconvenience to any client. These
privacy provisions apply to information that is considered nonpublic personal
information.
Nonpublic information includes personally identifiable financial
information and any list, description, or grouping that is derived from personally
identifiable financial information.
Personally identifiable financial information includes the following
three categories of information:
- Information Supplied by Client. Any information that is provided
by a client or prospective client to LFC in order to obtain a financial product
or service. This would include information or material given to LFC when entering
into an investment advisory agreement.
- Information Resulting from Transaction. Any information that
results from a transaction with the client or any services performed for the
client. This category would include information about account balances, securities
positions, or financial products purchased or sold through a broker/dealer.
- Information Obtained in Providing Products or Services. Any
information obtained by LFC from a client report or other outside source which
is used by LFC to verify information that a client or prospective client has
given on an application for advisory services.
To Whom We Disclose This Information
LFC does not disclose any of the nonpublic personal information described above
about any clients except as necessary in order to establish and manage the client's
account(s), or as directed by the clients to their CPA's, attorneys, insurance
agents, mortgage brokers, bankers, pension consultants/actuaries, and bookkeepers,
or as permitted by law (e.g., to government regulatory agencies). A client will
often complete application documents that may pass through LFC for forwarding
to other financial agencies such as Charles Schwab, Sterling Trust, or other
investment management entities for their use in establishing accounts on a client's
behalf. Those agencies have their own privacy policies, which they share with
their clients and customers.
Confidentiality and Security
LFC will restrict access to a client's non-personal financial information to
those employees who need to know such information in order to provide information,
products, or services to clients. LFC maintains physical, electronic, and procedural
safeguards that comply with federal standards to protect the confidentiality
of each client's personal financial information. Such safeguards include restricting
information contained in the Client Investment Questionnaire to each client's
personal account manager, the manager's supervisor, and LFC's Chief Compliance Officer
or such other persons as the Chief Compliance Officer deems necessary to know and
access the information. Hard copies of clients' personal financial information
will be maintained in LFC's central files, and will be secured (locked) after
normal business hours. Electronic access (local area network, LAN) to clients'
personal financial information is restricted to LFC employees only.
Privacy Notice
Each client will be provided with a copy of LFC's Privacy Notice upon opening
his or her account. In addition, each active client of LFC will be provided
with a copy of the Privacy Notice within 90 days following the close of LFC's
fiscal year. Clients may request a copy of the Privacy Notice at any time.
Release of Information
Clients may direct LFC to disclose their nonpublic, personal
financial information to any designated nonaffiliated, third party. The Securities
and Exchange Commission (SEC) refers to this as an opt out provision. Clients
may request that LFC disclose personal information by one of the following methods:
Mail. LFC will mail a copy of this Privacy Notice to each client.
A client may return the Privacy Notice indicating their instructions to LFC
to disclose information, or by calling LFC's main office at (800) 960-1703 within
thirty (30) days after the date the notice was mailed.
Isolated Transactions with Clients. Clients may instruct LFC
to disclose personal information at the time of any specific, isolated transactions
prior to or at the time of the transaction.
Partial Disclosure. Clients may select only certain parts of
their nonpublic, personal information be disclosed to a specific nonaffiliated,
third party.
Clients may instruct LFC to release all or certain parts of their nonpublic, personal
information by providing the name and contact information of the party (or
parties) to whom the information is to be sent. The information should be sent to LFC, Attention:
Chief Compliance Officer, 12222
Merit Drive, Suite 1500, Dallas, Texas 75251.
Questions
Questions regarding LFC's privacy policy should be directed to the Chief Compliance Officer at (800) 960-1703.

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