Under the Fair Credit Reporting Act and the Gramm-Leach-Bliley Act, also known as the Financial Modernization Act adopted by the United States Congress in 1999, you may direct us not to share certain information with our Practice Groups, including the non-public personal information you provide to us or that we obtain from non-affiliated third parties. If you do not want such non-public personal information shared, you may write us at the address listed at the end of this notice or call us at the toll free number to request that such non-public personal information not be shared with a Practice Group’s affiliates. Please provide your name, address, Social Security number or Employer Identification Number and account number(s), if applicable, with any such request. Your request not to share non-public personal information does not include information we are permitted by law to share with our affiliates, such as information related solely to our experiences or transactions with you and information which must be shared with non-affiliated third parties who are assisting us by performing services or functions on our behalf or who provide products and/or services requested by you, such as agents, insurance companies, administrators and service providers.
Designated Privacy Office:
Cambridge Consulting Group
101 West Big Beaver Road, Suite 600 Troy, Michigan 48084
T: 248.743.4300 F: 248.743.4301
Cambridge values the trust and confidence of its clients. Cambridge consists of three Practice Groups, Cambridge Wealth Strategies, Cambridge Benefits Consulting, and Cambridge Risk Management (each a “Practice Group” and collectively“Cambridge”). To provide you with the most effective and convenient access to our broad range of products and services, Cambridge must maintain information about its clients. Keeping client information secure and confidential is one of Cambridge’s top priorities. The purpose of this notice is to let you know how we collect information about you, the type of information we collect and what we may disclose to our affiliates and non-affiliated third parties. It also details the steps we take to protect non-public personal information. You do not need to take any action as a result of this notice, but you do have certain rights as described in the next sections.
COLLECTION OF INFORMATION
To conduct our business, Cambridge must collect a certain amount of information to provide client service, offer new products or services, administer our products and services, and fulfill legal and regulatory requirements. Specific language and examples may not apply to all clients, and the information we collect varies accordingly. Examples include: information on your application and related forms, such as name, address, date of birth, Social Security and/or Employer Identification Numbers, gender, marital status, organizational structure, assets, income, and investment option elections; information about you relationship with us, such as products or services purchased, account balances, benefit plans and payment history; information provided by you and/or your employer, benefits plan sponsor or association regarding Social Security Number, Employer Identification Number, age, income and marital status; information from other sources, such as demographic information; and medical or health information provided by you.
SHARING AND USE OF INFORMATION
While acknowledging the importance of protecting client information, we may find it necessary in the course of conducting business to disclose information we collect about you, as described above, in some or all of the following circumstances:
• Information may be shared among Practice Groups to enable them to provide client service or account maintenance. Information may be shared with non-affiliated third parties (as permitted by law) who are assisting us by performing services or functions on our behalf, such as agents, brokers, brokerage firms, insurance companies, administrators and service providers;
• Information may be shared with other financial service companies, such as banks, insurance companies and securities brokers or dealers, with whom we have joint marketing agreements; and
• Information may be shared with non-affiliated third parties as permitted or required by law, such as compliance with a subpoena, fraud prevention or compliance with an inquiry from a government agency or regulator.
Notwithstanding the foregoing, Protected Health Information, defined as individually identifiable health information, will only be shared or disclosed in compliance with applicable laws and regulations. We will not share personal health information, whether Protected Health Information or otherwise, for marketing purposes.
Subject to the clarification below, non-public personal information about you collected and/or maintained by a Practice Group may be shared with other Practice Groups so they may tell you about other products or services offered that might be beneficial to you. Provided, however, prior to any such disclosure you will be notified in advance of the proposed sharing of such information and the basis upon which such information will be disclosed, and you will be given the opportunity to direct in writing that the Practice Group not share this information with another Practice Group. We do not sell your information to third parties, and each Practice Group will disclose your personal information only as necessary to provide and service the products and services offered to you by that Practice Group.
PROTECTING THE INFORMATION
We are committed to maintaining the security and confidentiality of our clients’ personal information. To ensure such information is used only in the manner we have described in this policy, we have instituted the following safeguards:
• Employees of each Practice Group are required to comply with our established privacy policies and procedures, which exist to protect the confidentiality of client information.
• Employees of each Practice Group access the information only on a business need-to-know basis, such as to procure a life insurance or annuity policy, administer a plan, or service a client request.
• An employee of a Practice Group cannot access the non-public personal information of a client maintained by another Practice Group unless the client has been given notice of the proposed sharing of such information with the other Practice Group and the opportunity to direct that such information not be disclosed to the other Practice Group, and the client has not directed the Practice Group not to share this information with another Practice Group.
We require that third parties to whom disclosure is required to provide our products and services comply with our confidentiality and privacy requirements. We use physical, electronic and procedural safeguards and security procedures to maintain the confidentiality of the information we collect to guard against its unauthorized access or use and to comply with federal and state regulations to safeguard all non-public personal information. Such methods include locked files, user authentication and firewall technology.
REVIEW AND ACCESS TO YOUR INFORMATION
If required by law and upon your written request, each Practice Group of which you are a client will make information from your file available for your review. However, we are unable to provide information collected in connection with, or in anticipation of, any claim or lawsuit.
If you notify Cambridge or any Practice Group that any information is incorrect, we will review it. If we agree, we will correct our records. If we do not agree, you may submit a short statement of dispute, which will be included in any future disclosure of information. If you have any questions about the right of access, wish to access your file (as permitted by law) or wish to elect not to have your credit and/or other non-public personal information shared with our affiliates in accordance with the foregoing, please contact us at the toll free number or address listed on the back and provide your name, address, and Social Security Number or Employer Identification Number.