Privacy Policy

Privacy Notice Regarding Client Privacy

Maintaining the trust and confidence of our clients is a high priority. That is why we want you to understand how we protect your privacy when we collect and use information about you, and the steps that we take to safeguard that information. This notice is provided to you on behalf of Chatterton & Associates, The Wealth Management Team, Inc.

Changes to this Policy

We may revise this policy at our discretion and will update it periodically. Your continued use of our websites and services after changes have been posted will constitute your acceptance of this Privacy Policy and changes

Information We Collect: In connection with providing investment products, financial advice, or other services, we obtain non-public personal information about you.

For purposes of this policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly with a particular consumer or household. It does not include de-identified or aggregate information, or public information lawfully available from governmental records.

Below we categorize types of personal information we have collected or will collect from you during our relationship. We may continue to collect these types of personal information and use it for the purpose listed below. Please note that the examples of the types of information within these categories that may qualify as personal information are not intended to be comprehensive and that there may be overlap between categories.

Categories of Personal Information

Contact information and other personal identifiers, such as name, postal and email address, phone number, unique personal identifier, account name, registration number, tax identification number, Social Security number, driver’s license number, passport number, and similar identifiers
Financial, commercial and benefits information, such as records and information about personal property or financial accounts, investments, products, and services, purchasing; investment objectives, risk tolerance, time horizon, assets, holdings and financial interest, income and compensation, expenses, tax information, transaction history, investment experience; other account information; information on savings, insurance, and retirement; other benefits related information; and other commercial and financial information
Internet or electronic activity information and device and online identifiers, such as IP address, online identifier or device ID, or other similar identifiers; information regarding interaction with a website, device, database, or application, including time and duration of internet and network connections; browsing history; and calls and emails sent and received
Demographic, protected classification, and association information, such as date of birth/age, gender, marital status, citizenship and visa status, military or veteran status; association-related information, such as whether an individual is related to someone who is employed in the securities industry, information about dependents, beneficiaries, and parties related to an account, trusted contact person(s); and disability and health-related information
Audio, electronic, visual or similar information, including photographs, CCTV footage and other video event recordings, and voicemail
Inferences drawn from personal information to create a profile in relation to preferences, credit history, risk tolerance, and investment strategies
Other personal information provided to us or stored on our systems, such as information provided by email or in a phone call

How We Use Information: Information may be used among the Non-Affiliated companies that perform support services for us, such as data processing, technical systems consultants and programmers, or companies that help us market products and services to you for a number of purposes, such as:

To process your requests such as securities purchases and sales
To help you establish or maintain an account with an unaffiliated third party, such as a clearing broker-dealer providing services to you
To service your accounts, such as conducting transactions, communicating, fulfilling requests and responding to questions, providing information and events, providing financial advice, conducting administrative and managerial tasks associated with our client services
To supervise and provide compliance and educational support to Advisors
To comply with Federal, State, and Self-Regulatory Organization requirements; and
To keep you informed about financial services of interest to you
To protect your accountsfrom unauthorized access or identity theft, ensuring the security and sufficiency of our networks, systems, services, property and personnel, monitoring, assessing, designing and improving our operations and managing risk

Categories of Information We Disclose: We may disclose all information that we collect as required by law. Chatterton & Associates and its affiliates do not sell customer lists and will not sell your name to telemarketers.

Categories of Parties to Whom We Disclose: We will not disclose information regarding you or your account with us, except under the following circumstances:

To your authorized Advisor and his or her manager
To our Broker/Dealer that our Advisors are associated with and the Broker/Dealer’s affiliates, to the extent required and/or permitted by law
To entities that perform services for us or function on our behalf, including financial service providers, such as a clearing broker-dealer, investment company, or insurance company
To consumer reporting agencies
To third parties who perform services or marketing on our behalf
To your attorney, trustee or anyone else who represents you in a fiduciary capacity with your written approval
To our attorneys, accountants or auditors
To government entities or other third parties in response to subpoenas or other legal process as required by law or to comply with regulatory inquiries
We may disclose non-public personal information about you in connection with the transfer of your account to another financial institution at your request or the request of your advisor. If you do not want Chatterton & Associates to disclose your non-public personal information with your advisor’s new financial institution, please contact us as directed below
Other parties to which your direct us to disclose personal information

Sources of Personal Information

We collect or receive the categories of personal information above from:

Communications and interactions with individuals seeking to obtain or using our products and services or their agents and representatives, or other persons communicating or otherwise interacting with us
Automated collection through our Sites, services, products, applications, databases, devices, information systems and networks, including through cookies and similar technology
Other financial institutions, product sponsors, clearing firms, intermediaries, business partners and contacts
Service providers, contractors, vendors,
Subscription information, research and analytic services
Public and government sources and records
Records and property to which we have lawful access, e.g., device inventories for company property or documents stored on our systems

Marketing and Website Analytics

Cookies and Marketing

We may use data collected from our websites to make you personalized offers relating to our services, either on our websites or on third-party sites that you visit through the use of cookies and similar technologies in conjunction with other entities (e.g., Google Ads and social media partners). A cookie is a file with a small amount of data that is sent to your browser from a web server and stored on your device. If you are interested in learning more about online behavioral advertising, or opting out of this type of advertising, we encourage you to visit one of the advertising industry-developed opt-out pages, such as https://youradchoices.com/ or https://aboutads/info. (Note, however, that these and other links we provide in this policy to other entities’ sites are sites over which we have no control.) For more information on GoogleAds, and the information Google collects through this service and cookies as may be amended from time to time, please refer to the Google links below.

Analytics

Our websites may also use cookies to track website behavior and place cookies that may allow us to connect that information to other information that we have about you and track how visitors access or view our websites. We use this information to understand what pages and features of our websites visitors find useful. We use Google Analytics for this purpose. For more information about Google, the information it collects, and Google Analytics’ Opt-Out Browser Add-On, please visit:

Do Not Track Requests

Currently there is no industry standard for “Do Not Track” signals, which are options on your browser that tell website operators that you do not wish to have online activity tracked. Because there is no industry standard concerning what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals

Sales of Information

We do not and will not sell personal information, nor have we sold any of the categories of described above

Regulation S-ID: Regulation S-ID requires our firm to have an Identity Theft Protection Program (ITPP) that controls reasonably foreseeable risks to customers or to the safety and soundness of our firm from identity theft. We have developed an ITPP to adequately identify and detect potential red-flags to prevent and mitigate identity theft.

Our Security Policy: We restrict access to nonpublic personal information about you to those individuals who need to know that information to provide products or services to you and perform their respective duties. We maintain physical, electronic, and procedural security measures to safeguard confidential client information.

Closed or Inactive Accounts: If you decide to close your account(s) or become an inactive customer, our Privacy Policy will continue to apply to you. Individuals may also request that we delete personal information. Upon receiving and verifying such a request, Chatterton & Associates will delete the personal information unless the information is necessary for Chatterton & Associates to:

Complete the transaction for which we collected the information
Provide you with the good or service that you requested
Detect security incidents

How We Protect Personal Information

Chatterton & Associates is committed to the security of your personal information. To protect personal information from unauthorized access and use, we implement and maintain reasonable security measures that are intended to maintain the confidentiality of personal information. However, no security measures are infallible and we cannot and do not guarantee that our safeguards will always work. Please always use caution when transmitting information, including over the internet, use strong and unique passwords that your do not also use on other online services, and notify us immediately of any concerns regarding your account or passwords.

Additional Information for California Residents

This section supplements the information contained in the other sections of the Privacy Notice and applies solely to clients, visitors, users, and others who reside in the state of California (“consumers” or “you”) and for whom we have data that are subject to the California Consumer Privacy Act of 2018 as may be amended or supplemented from time to time (“CCPA”). This Privacy Notice, including this additional information, is provided to comply with the CCPA and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this section.

It is important to note, however, that the CCPA does not apply to all entities, nor does it apply to Personal Information maintained by financial services firms that are covered under certain exemptions described in the CCPA, and as such, the CCPA may not apply to Personal Information we maintain about you.

For the 12-month period prior to the date of this Privacy Notice, we have not “sold” (as that term is defined under the CCPA) any of your information.

Depending upon how you interact with us, you may have various rights in connection with our processing of your Personal Information, each of which is explained below.

Access. You may have the right to confirm with us whether your Personal Information is processed and, if it is, to request access to that Personal Information, including the categories of Personal Information processed, the purpose of the processing, and the recipients or categories of recipients. We do have to consider the interests of others though, so this is not an absolute right and there are additional exceptions under the CCPA. Also, we are not obligated to respond to more than two access requests for the same individual’s Personal Information within any 12- month period.
Deletion. You may have the right to ask us to erase Personal Information concerning you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise, or defend legal claims or under other exceptions under the CCPA.

If your request is for data relating to you that is de-identified or aggregated so that it is no longer Personal Information, we are not required to re-identify the data to respond to your request. You have a right to receive nondiscriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

Making your own privacy rights request: To exercise one or more of these rights, please contact us as explained below. Please note that we may need to verify your identity before we can fulfill your request. Verification can involve matching up to three pieces of your personal data (as provided on your request) with our internal records. You can submit your request via email or by calling us – please refer to our contact information below.

Authorized agent requests: An access and/or deletion request also may be made by someone else you authorize specifically to make such a request under the CCPA or by someone you have named as your agent under a power of attorney that is valid under the California Probate Code.

Handling requests we receive: If we need additional information to verify your identity, we will let you know. We will endeavor to respond to a verified request within 45 days, unless there are grounds for extending our response timeframe by up to an additional 45 days. In the event of an extension, we will explain to you why the extension is necessary. In some cases, your ability to access or delete your Personal Information will be limited, as required or permitted by applicable law, even when the CCPA applies to the Personal Information we have for you. If we cannot fulfill your request because we cannot verify your identity or due to exceptions under the CCPA (or when the CCPA does not apply to the Personal Information), we'll let you know in our response.

Changes to This Privacy Policy: If we make any substantial changes in the way we use or disseminate confidential information, we will notify you.

Contact Information: You may notify us of any questions or concerns, by one of the following methods:

Mail

Chatterton & Associates, The Wealth Management Team, Inc.
3061 E. La Palma Ave.
Anaheim, CA 92806

Telephone

(714) 572-2050

Email

contactus@chattertoninc.com