OUR COMMITMENT TO PRIVACY
In the course of our business, we gain access to business and financial information of our clients and prospective clients, including personal information of the individuals who are in control of or who own them. We are committed to maintaining the confidentiality of that information. We collect, maintain, use, and share information about our clients, prospective clients and their control persons only where we reasonably believe that it will help administer our business or provide services and other opportunities to our clients. We do not sell or share client, prospective client, or former client lists or personal information to list brokers, marketing firms or to other third parties for their own marketing purposes.
COLLECTION OF INFORMATION
There are some disclosures to third parties that we must make, such as disclosures necessary to effect, administer or enforce a transaction requested by you, to companies that perform services for us or to prevent fraud. Those disclosures may consist of the following:
- Financial background information describing a client or person’s financial status.
- Identification information, such as name and address data.
- Transaction information, such as account activity, debit activity or credit activity.
- Other information relating to financial matters.
RECIPIENTS OF INFORMATION
- Financial institutions, such as banks.
- Companies that process transactions or provide other services for us.
- Government agencies.
- In addition, under federal law we are permitted to disclose confidential information to certain recipients, such as credit reporting companies.
EMPLOYEE, VENDOR AND CONTRACTOR ACCESS TO INFORMATION
We limit access to confidential information to employees of ours who need it to fulfill their business responsibilities. Employees must adhere to our privacy policies. Employees violating these policies may be subject to disciplinary action, up to and including dismissal. Vendors and other outside contractors we engage are subject to our contractual requirements to ensure that sensitive confidential information is safeguarded.
WE USE APPROPRIATE SECURITY SAFEGUARDS
Security is a priority at Delve. We employ appropriate measures to protect confidential information against unauthorized access, disclosure, alteration or destruction. These may include, among others, encryption, physical access security and other appropriate technologies. We continually review and enhance our security systems, as necessary.