|
This statement describes Alaskan Auto Custodian LLC's privacy policy and the practices that will be followed
to respect the privacy of individuals who deal with Alaskan
Auto Custodian LLC. Your
privacy is important to us, and maintaining your trust and confidence is one of
our highest priorities. We respect your right to keep your personal information
confidential and understand your desire to avoid unwanted marketing solicitations
and invasions of your privacy. Federal and State laws requires us (along with
other companies, including banks, brokerage houses, and other financial institutions)
to disclose our Privacy Policy to you which is contained in the balance of this
document. We have prepared this policy to explain what types of information
we collect, how we use it, under what circumstances we may share it, and other important
information. This policy covers all the entities and activities controlled by Alaskan Auto Custodian LLC (hereinafter referred to as “AAC”).
Under no circumstance do we provide personal information to non-AAC entities for
the purpose of independent telemarketing or direct mail marketing of any product
or service of these companies. In fact, we do not disclose any information
except in the limited situations described in this document.
This notice takes effect May 1, 2007 and will remain in effect until we replace
or revise it. If we change our privacy policy and practices, we will prepare
written notice as well as post it on our website. We reserve the right to
change our privacy practices and the terms of this notice at any time, provided
such changes are permitted by applicable law. You may request a copy of our
privacy policy notice at any time. For more information about our privacy
practices, or for additional copies of this notice, please contact us using the
information listed at the end of this notice. If you received this notice
at our Internet website or by electronic mail, you are entitled to receive this
notice in written form if you contact us using the information listed at the end
of this notice.
Collection of Information
The type of information collected by Alaskan Auto Custodian LLC (AAC) regarding individuals
and businesses generally includes the following: names, addresses (including
email addresses), telephone and facsimile numbers, date of birth, occupation, details
about an individual’s family (including spouse and children’s names, birthdays and
genders) and financial details and concerns. Through our collection of this
information, information about gender, education, medical history, social preferences
and membership in professional, political and/or social associations/interests may
come to be known by us and this is discussed in additional detail in the following
paragraph. The information held by AAC may come from a number of sources including
interviews and phone calls with you, publicly available sources, letters and/or
e-mails to/from you, tax returns, organizers, tax return source documents, financial
history questionnaires and receipts, books of record and, for example, cancelled
checks, receipts and bank statements. We collect personal information about
you, but only when that information is provided by you or is obtained by us with
your authorization or through direct interaction with you. We use all information
that we gather to prepare your income tax returns and may also use it to provide
various tax, consulting and financial planning services to you at your request.
Some information AAC holds may be “Sensitive Information”
Because the data necessary to prepare tax returns and to provide various tax, consulting
and financial planning services is obviously very personal and highly confidential,
sensitive information will obviously come to our attention and knowledge.
“Sensitive Information” is information or an opinion about an individual’s
race or ethnic origin, gender, education, medical history, social and political
opinions, membership in political associations, religious beliefs and affiliations,
philosophical beliefs, memberships in professional or trade associations or trade
unions, sexual preferences or practices and/or criminal records. AAC will only receive
sensitive information with the individual’s consent through direct discussion or
document examination. AAC will not overtly collect personal information unless
the information is necessary for one or more of its functions or activities. AAC
will collect the personal information only by lawful and fair means and not in an
unreasonably intrusive way. Whenever AAC collects personal information about an
individual, AAC will take reasonable steps to ensure that the individual is aware
of the identity of AAC, the fact that he or she is able to gain access to the information
and the purpose for which the information is collected. AAC cannot, however,
be held responsible for inadvertently learning sensitive information through discussions
that are initiated by you or documents presented to us by you but will, of course,
treat such information in the same manner as all other information that we know
about you.
The Purposes for which AAC uses this Information
The purposes for which AAC uses personal information collected includes the following: to
open and administer client accounts, to provide financial services to clients, to
administer and supervise employees and independent contractors of our firm, for
marketing and sales initiatives such as AAC publications, brochures, newsletters
and business and personal networking events, to promote events in the community
with which AAC is associated, for billing and collection activities and related
data processing and to consider potential employee’s applications for employment
by the Firm.
Use and Disclosure
We do not disclose personal information about our clients or former clients to anyone.
However, to the extent permitted by law and any applicable state Codes of Professional
Conduct, certain nonpublic information about you may be disclosed in the following
specific situations:
1.
To comply with a validly issued and enforceable subpoena, warrant or summons.
2.
In the course of a review of our firm's practices under the authorization of a state
or national licensing board, or as necessary to properly respond to an inquiry or
complaint from such a licensing board or organization.
3.
As a part of any actual or threatened legal proceedings or alternative dispute resolution
proceedings either initiated by or against us, provided we disclose only the information necessary
to file, pursue, or defend against the lawsuit or action but to take reasonable
precautions to ensure that the information disclosed does not become a matter of
public record.
4.
To provide information to affiliates of the firm and nonaffiliated third parties
who perform services or functions for us in conjunction with our services to you,
but only if we have a contractual agreement with the other party, which prohibits
them from disclosing or using the information for other than the purposes, for which
it was disclosed.
5.
In conjunction with the normal due diligence process of any merger, provided that
we take appropriate precautions (for example, through a written confidentiality
agreement) so the prospective merger partner does not disclose information obtained
in the course of the process.
6.
To report information related to victims of abuse, neglect or domestic violence.
7.
To assist law enforcement or public health officials avert a serious threat to the health
or safety of you or any other person.
8.
Information may be disclosed to lawfully established executors or administrators to enable them
to carry out their lawful duties.
As a general rule,
AAC will not use or disclose personal information about an individual
other than for its primary purpose of collection, unless the individual has consented
to the use or disclosure. AAC will use the information it gathers for our own direct
marketing purposes only where it is impractical for AAC to seek the individual’s
consent before that particular use. AAC will not charge an individual for giving
consideration to a request not to receive direct marketing communications if the
individual makes a request not to receive direct marketing communications.
Data Quality and Data Security
AAC will take reasonable steps to make sure that the personal information it collects,
uses or discloses is accurate, complete and up-to-date. AAC will take reasonable
steps to protect the personal information it holds from misuse and loss and from
unauthorized access, modification or disclosure. AAC will take reasonable steps
to destroy or permanently de-identify personal information if it is no longer needed.
Openness, Access and Correction
AAC employees and professional independent contractors are permitted to access the
information they need to perform their jobs. We maintain strict internal policies
against unauthorized disclosure or use of client information. Information held by
any AAC related entity is available to other members of the AAC family of entities
for authorized purposes. AAC has set out in this document its policies on management
of personal information and will make this document available to anyone who asks
for it. AAC will take reasonable steps to let the requestor know, generally, what
sort of personal information we hold, for what purposes, and how we collect, hold,
use and disclose that information. As a general rule, AAC will, on request by an
individual or business, provide them with access to their personal or business information,
however AAC may choose not to provide individuals or businesses with access to such
information. This would include cases where providing access would have an unreasonable
impact on the privacy of other individuals or businesses, the request for access
is frivolous or vexatious, the information relates to anticipated or existing legal
proceedings and would not be discoverable in those proceedings, providing access
would reveal the intentions of AAC, AAC in relation to negotiations with the individual
in such a way as to prejudice those negotiations, providing access would be unlawful,
providing access would be likely to prejudice an investigation of possible unlawful
activity or providing access would be likely to prejudice activities which are carried
out by AAC on behalf of an enforcement body. AAC will impose a charge to cover the
cost of verifying and complying with all requests for information, including compliance
with a validly issued and enforceable subpoena or summons and for locating, retrieving,
reviewing, couriering and copying any material requested. The charge will be levied
on the client whose records we are asked to produce but we will reasonably cooperate
in assisting the client in recovering such costs from the requesting party if that
party is not the client but, ultimately the responsibility for information production
will always remain with our client and such charges are always expected to be paid
promptly.
Identifiers and Anonymity
AAC will not adopt a government agency identifier (such as a tax file number or
driver’s license number) as its identifier of an individual. Wherever it is lawful
and practical, AAC will allow individuals the option of not identifying themselves
when entering into transactions or discussions with us.
Transborder data flows
AAC will only transfer personal information about an individual to a third party
who is in a foreign country in specified circumstances. This would include where
the individual consents to the transfer or where AAC has taken reasonable steps
to ensure that the information that it has transferred will not be held, used or
disclosed by the recipient of the information inconsistently with our privacy policy.
Confidentiality and Security of Non-Public Information
Except as otherwise described in this notice, we restrict access to nonpublic personal
information about you to employees and professional independent contractors of our
firm and other parties who must use that information to provide our services to
you. Their right to further disclose and use the information is limited by the policies
of our firm, applicable law, our Code of Professional Conduct, and nondisclosure
agreements where appropriate. We also maintain physical, electronic, and procedural
safeguards in compliance with applicable laws and regulations to guard your personal
information from unauthorized access, alteration, or premature destruction.
How can an Individual Complain about Possible Breaches of Privacy by AAC?
A complaint by an individual regarding an alleged breach of privacy by AAC
should be forwarded in writing by certified mail to the following address: Privacy
Complaints Officer, Richard Pointer, 3504 Industrial Avenue 219, Fairbanks, Alaskan
99701. The Privacy Complaints Officer will be made available to investigate and
resolve the complaint internally through mediation with the affected individual.
This contact information may also be used to communicate with us if you have any
questions, comments or concerns regarding our privacy policy or this notice.
|