PRIVACY POLICY

Investment advisers are required by law to inform their clients of their policies regarding the privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law.

 

Federal law gives the customer the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information.

 

Our firm is committed to safeguarding the privacy of our clients' information. As investment advisers registered under state and federal law, we uphold our obligation to inform our clients of our stringent privacy practices. This document details our approach to handling and protecting personal and financial information entrusted to us.

 

Client’s Information Collection: We, our affiliates and our third- party service providers, collect a range of nonpublic personal information (NPI) about you that is either provided to us by you or obtained with your authorization. It is essential for managing your account and providing you with the highest financial service. When you are no longer our customer, we may continue to share your information only as described in this notice; however, you can contact us anytime to limit our sharing. This information is gathered through the following methods:

• Directly from client interactions, inquiries, and consultations.

• From documents and forms clients complete, including applications, agreements, and other financial documentation.

• Through transactions within your accounts, including account balances, investments, withdrawals, and payment history.

• Via technology-based tools and analytics, including website cookies and other online data-gathering mechanisms, to understand how you use our services.

• From third-party entities, including consumer reporting agencies, for the verification of client identity, background, creditworthiness, and other due diligence purposes.

 

Information We Collect May Comprise: Including but not limited to:

• Identifiers include Social Security Number, Driver's License Number, and Passport Number.

• Contact details, including addresses, telephone numbers, and email addresses.

• Financial profiles, including net worth, assets, income, expenses, investment experience, and risk tolerance.

• Employment information, including position, tenure, and employer identity.

• Banking, investment, and credit account information, including account numbers, balance information, and payment history.

• Insurance policy details and coverage information.

• Beneficiary and estate planning information, including trust agreements and wills.

• Utility bills, bank statements, and other.

• Entities information, such as companies and trust formation documents, good standing letters, shares certificates, and bank statements.

 

Use and Disclosure of Information: All Investment Advisers may need to share personal information to run their everyday business. The section below lists why we may share your personal information. Our firm restricts the use and disclosure of NPI to the following scenarios:

• To affiliates and non-affiliated service providers to manage client accounts and provide requested financial services, subject to stringent confidentiality agreements.

• To third-party service providers who assist us in processing transactions, such as custodians, broker-dealers, financial institutions, and financial technology companies that enable us to provide services.

• To comply with legal, regulatory, and audit requirements, including but not limited to responding to court orders, legal investigations, and regulatory inquiries.

• To credit bureaus and other third parties in connection with determining creditworthiness.

• As permitted or required by law, including to prevent fraud or to respond to a subpoena.

• To affiliated and non-affiliated parties for marketing purposes, provided clients have not opted out of such sharing.

 

Client Rights and Choices: Clients possess the following rights concerning their NPI:

• The right to opt out of sharing their NPI with non-affiliated third parties for marketing purposes.

• The right to opt-out of certain disclosures to affiliates regarding creditworthiness or for their marketing purposes.

• The right to be informed of any changes to our privacy policy annually and as significant changes occur.

 

Protecting the Confidentiality of Current and Former Client’s Information: To protect your personal information from unauthorized access and use, we, our affiliates, and third-party service providers use security measures that comply with federal law, including computer safeguards and secured files and buildings. Our affiliates and service partners employ comprehensive security measures to protect NPI from unauthorized access or disclosure. These include:

• Digital security systems, including encryption, firewalls, and intrusion detection systems.

• Physical security measures include secured access to our buildings and secure document disposal.

• Internal policies governing the appropriate use and handling of NPI.

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Continuation of Policy After Termination of the Client Relationship: Our duty to protect and maintain the confidentiality of client NPI persists even after the client-advisor relationship has ended.

 

Engagement with Third-Party Service Providers: We engage with various third-party financial and technological service companies and other financial entities while providing comprehensive financial services. These third parties are integral to our operations and assist us in multiple capacities, including but not limited to:

• Account management and investment services, facilitating transactions, custodial services, and maintaining accurate and secure client records.

• Financial planning and analysis, offering tools and insights for creating strategic financial plans tailored to client goals.

• Generating reports related to investments, portfolio performance, and financial planning.

• Producing investment tax reports, ensuring compliance with tax regulations, and facilitating accurate tax reporting for our clients.

• Compliance with legal and regulatory requirements aids in adhering to the laws and regulations governing our industry.

• Electronic communication via email, instant messaging, websites, and data archiving

 

Data Collection and Management by Third-Party Systems: These third-party service providers may utilize advanced technology systems that collect and store data as part of their service offerings. This can include, but is not limited to:

• Electronic data capture through secure online platforms and interfaces.

• Store client data in secure cloud-based systems, protected with encryption and other cybersecurity measures.

• Analytical tools that process and analyze financial data to provide insights and reports.

• Compliance and regulatory technology to ensure adherence to applicable laws and regulatory standards.

 

Due Diligence and Oversight: We conduct thorough due diligence when selecting third-party service providers to ensure they have robust privacy and security policies. We require these providers to agree to strict data protection and confidentiality terms. Our firm maintains oversight of the data management practices of these third parties to ensure ongoing compliance with our high data protection and privacy standards.

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Client Consent and Rights: We will inform clients of third-party engagements involving access to their NPI and obtain consent where the law requires it. Clients have the right to opt out of any data sharing that is not essential to the servicing of their account or required by law.

Federal law allows you the right to limit the sharing of your NPI by “opting out” of the following: sharing for non-affiliates everyday business purposes – information about your creditworthiness; sharing with affiliates who use your information to market to you or sharing with non-affiliates to market to you. State laws and individual companies may give you additional rights to limit sharing. Please notify us immediately if you choose to opt out of these types of sharing.

 

Definitions:

• Affiliates are companies related by common ownership or control. They can be financial and non-financial companies.

• Non-affiliates – Companies not related by common ownership or control. They can be financial and non-financial companies.

• Joint marketing – a formal agreement between non-affiliated financial companies that together market financial products or services to you

• Third-party service providers – financial, technological, or service companies hired to work together to provide clients with our financial services.

Updates and Inquiries: Clients will receive notices of updates to this privacy policy as required by law. Should you have any questions regarding this policy, please contact us at your convenience using the contact information below.

 

Please call if you have any questions. Your privacy, our professional ethics, and our ability to provide you with quality financial services are essential to us.

 

Mellig Group, LLC

 

8350 Ashlane Way, Suite Forth Worth, The Woodlands, Texas 77382

+1 (281) 206-8856

 

400 University Dr, Suite 400, Coral Gables, Florida 33134

+1 (786) 629-5093

 

contact@mellig.us www.mellig.us

 

March 5th, 2024