June 1, 2001
Pennaluna & Company has been protecting customer privacy for many
years. This will tell you more about our commitment to your privacy, in accordance with
new SEC Regulation S-P.
We don't ever sell customer information
Pennaluna & Company does not ever sell any
type of personal customer information. This includes nonpublic personal information.
Information we may have
To help us give you good service and in order to fulfill obligations
imposed on us by law or regulation, we may receive information about you from various
sources, including, for example:
your requests for our products or services, which may provide such data
as your physical or email address, financial situation, social security number, and other
information you might enter on a new account application, for instance
your transactions with us or our securities clearing firm, which may
provide such data as your account balances, transaction record, payment history and other
information
consumer reporting agencies, for your credit history or other
information regarding creditworthiness for margin lending or other transactions, and other
outside parties in order to verify representations concerning employment, loan balances
and so forth
How we may share it
Pennaluna may share information it has about you only as lawfully
permitted or required for legal or routine business reasons, including maintaining or
servicing your account. For instance, we may share information: with regulatory and law
enforcement authorities; pursuant to legal process or to protect against fraud; with our
securities clearing firm in order to service your account and provide products and
services to you; and with anyone if you consent to that sharing, for instance if
you want us to release data to a possible lender.
Protection
We maintain physical, electronic and procedural safeguards to help keep
information protected from unauthorized access. We compile only the minimum information
reasonably necessary for us to meet our obligations to customers and to satisfy
requirements imposed by the government. We are a small firm with low employee turnover
where everyone knows each other well and works near one another; this helps us to monitor
proper use of data, detect misuse, and make sure information is accessed only by those who
need it to provide products or services to you.
Who our policy covers
This policy applies to consumers who are customers or former customers of
Pennaluna & Company.
