January 2018
SUMMARY
Delta Capital Management (DCM) takes your privacy very seriously. We share a commitment to protect your privacy and the confidentiality of your personal and financial information. We do not reveal, sell, or distribute any personal information to any party unless required by law to effect securities transactions in your account.
INTRODUCTION
As providers of products and services that involve compiling personal – and sometimes, sensitive – information, protecting the confidentiality of that information has been, and will continue to be, a top priority at Delta Capital Management. We believe that you should know about the information we collect, the measures we take to safeguard it, and the situations in which we are required to share information in our business. This brochure explains how DCM handles – and protects – the personal information we collect.
The information we collect and the extent to which we use it will vary depending on the product or service involved. In fact, in certain cases, we may not collect or share some of the types of information noted below. Our privacy promise derives from basic principles of trust, ethics and integrity:
1. We collect only the customer information necessary to consistently deliver responsive products and services. DCM collects information that helps serve your financial needs and fulfill legal and regulatory requirements. The information collected generally varies depending on the product or services you request and may include, information provided in personal interviews or contracts and related forms.
2. We maintain safeguards to ensure information security. We have implemented security standards and processes – including physical, electronic and procedural safeguards – to ensure that access to customer information is limited to employees and agents who may need it to do their job. They are required to respect the confidentiality of all customer information.
3. We limit how, and with whom we share customer information. First and foremost, we do not sell lists of our clients, nor do we disclose customer information to marketing companies. We will disclose client information only for the following reasons:
a. When it is necessary and required to disclose information to third parties in order to effect, administer or enforce a transaction that you request or authorize—for example, when we provide information to a broker/dealer with whom we transact.
b. We may be required by law or regulation to disclose information to third parties-- for example, in response to a subpoena, to prevent fraud, and to comply with rules of, or inquiries from industry regulators such as the United States Securities and Exchange Commission.
c. Furthermore, as required by federal and state laws, we may be required to share or exchange information with companies engaged to work with us, such as:
· Third-party administrators and vendors hired to effect administer or enforce a transaction that you request or authorize.
· Financial services entities, such as banks, credit unions, credit union service organizations, thrifts, thrift service organizations, insurance companies, or securities broker–dealers, with which we deal.
Other than what is described above we won’t share information about you with third parties to market products to you, unless you request.
We will reaffirm this policy annually in writing. Additionally, we are required to annually offer a copy of our most recent Securities and Exchange disclosure document to every client. This may be requested by calling us, in writing, or can be found on our Internet site (Form ADV Part II). Also, our proxy voting policy may be requested at any time.
In this notice of our Privacy Promise, the words “you” and “client” are used to mean any individual who obtains or has obtained a financial product or service from DCM. If any questions arise, please feel free to call us anytime.
