NOTICE OF PRIVACY PRACTICES
W. R. Gorman & Associates
W. R. Gorman & Associates has always been committed
to maintaining the strict confidentiality of personal information
regarding their clients and their clients' accounts. This
long-standing policy is now further enhanced by new rules
governing privacy of consumer financial information adopted
by the Securities and Exchange Commission (the "SEC
Rules"). Such rules, among other things, require initial
and annual privacy notices such as this Notice. The Company
(sometimes referred to in this Notice as "we"
or "us") value our relationship with you and recognize
that an essential element of that relationship is your trust
and confidence that the information you share with us will
be treated as private and confidential to the extent permitted
or required by law.
Set forth below in "bullet" form is a statement
of practices we follow in the collection, disclosure and
protection of information about you.
- Your "nonpublic personal information". As part
of our investment advisory and investment management business,
we obtain certain information about you. Such information
is defined in the SEC Rules as "nonpublic personal
information".
-
Sources of your "nonpublic personal
information". We obtain "nonpublic personal
information" about you from the following sources:
-
Information provided by you in the course
of attending meetings and conferences, on applications
and other forms, in contracts or documents, and in correspondence;
and
-
Information about your transactions with
us.
-
Access to and protection of your nonpublic
personal information. We employ procedures to safeguard
your nonpublic personal information. Access to your nonpublic
personal information (and the nonpublic personal information
of any other client, past or present) is restricted by
us to only those authorized individuals who need to know
this information in order for us to provide services or
products to you. We maintain physical, electronic, and
procedural safeguards that comply with federal standards
to guard and otherwise protect your nonpublic personal
information.
-
General disclosure policy. We may disclose
your confidential information (or the confidential information
of any other client, past or present) on a limited basis
to certain nonaffiliated third parties:
-
Where such disclosure is necessary to
process and service transactions which you have requested
or authorized or is necessary to service your account;
-
Where there is not a processing disclosure,
but such disclosure is permitted by law (examples being
disclosures (i) to protect the confidentiality or security
of our records relating to you, our services or our transactions
and (ii) to protect against or prevent actual or potential
fraud, unauthorized transactions, claims or other liability);
and
-
Where such disclosure (i) is to nonaffiliated
third parties which perform services on our behalf and
(ii) is the subject of a written agreement with the nonaffiliated
third parties pursuant to which such parties have agreed
to keep all information furnished to them confidential
and secure except as permitted by law.
You do not need to take any action as a result of this
Notice. This Notice is meant to confirm our confidentiality
commitment to you as part of maintaining the essential
element of trust in our relationship. We value our relationship
with you and strive to earn your continued trust. If you
have any question or concern, you may contact William
R. Gorman.
Effective as of March 30, 2004
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