This Privacy Notice relates to Totus Tuus Consulting, and its affiliates (collectively known as “TTC”). We acknowledge that the privacy of the data provided is of the ultimate importance to our clients and our prospective clients (“Data Subject”, “You”, “Your”).
Consequently, TTC considers the obligation to ensure the proper security of all personal data that passes through its control. This Privacy Notice (“Notice”) describes how TTC collects, uses, and discloses certain personally identifiable information that it receives. We only disclose nonpublic personal information about our clients or former clients to third parties in accordance with the provisions of this Notice. Therefore, please read this Notice carefully to understand what we do.
1. Personal information we collect.
We collect personal information about you in connection with our providing advisory services to you. Personal Information we collect will fall within one of the below categories:
· Social security number
· Investment experience;
· Transaction history;
· Income; and
· Wire transfer instructions.
2. How we collect this information.
We collect this information from you through various means. For example, when you give us your contact information, enter into an investment advisory contract with us, buy investment advisory services from us, tell us where to send money, or make a wire transfer. We may collect your personal information from other sources, such as our affiliates or other non-affiliated companies that are authorized to share your information with us.
3. What Does TTC Do with Your Personal Information?
All financial companies need to share customers’ personal information to run their everyday business and we use the personal information we collect from you for our everyday business purposes. Personal information we collect will be used for one or more of the following purposes:
· To provide advisory services to you.
· To open an account for you.
· To process a transaction for your account.
· To market products and services to you.
· To respond to court orders and legal investigations.
4. The Legal Basis for Using Your Personal Information
We will only collect, use and share your personal information where we are satisfied that there is a legitimate reason to do this. We will have one or more of the following reasons for using your personal information when such use:
is necessary to fulfill a contract we have with you or to enter into a contract with you
is necessary to comply with a legal obligation that we have, for example where we are required to report to tax authorities
is required for regulatory reasons that are in the public interest
is provided through your consent to us to use such information
is in our legitimate interest to provide services to our clients, provided our use is proportionate and respects your privacy rights.
Where TTC processes your personal information for legal, regulatory, and contractual purposes as outlined in this Notice, you acknowledge that failure to provide us with the personal information required, may result in TTC not being able to offer you services.
5. Disclosure to others.
Financial companies choose how they share your personal information. We may provide your personal information to our affiliates and to firms that assist us in servicing your account and have a need for such information, such as a broker or fund administrator. We may also disclose such information to service providers and financial institutions with whom we have joint marketing arrangements. We require third-party service providers and financial institutions with which we have joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them. Moreover, we may also share your information with agencies and organizations working to prevent fraud in financial services and with our regulators to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory, and other governmental agencies.
6. How we protect your personal information.
To protect your personal information from unauthorized access and use, we use security measures that comply with Federal law. These measures include computer safeguards and secured files and buildings designed to: (i) maintain the security and confidentiality; (ii) protect against any anticipated threats or hazards to the security or integrity; (iii) protect against unauthorized access to or use of such information that could result in substantial harm, and (iv) ensure appropriate disposal of such information.
7. Data Retention
We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this Notice. In some circumstances, we may store your personal information for longer periods of time, where we are required to do so in accordance with legal, regulatory, tax, accounting, or necessary technical requirements.
In specific circumstances, we may store your personal information for longer periods of time, if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
8. Updates or Amendments
We reserve the right to modify this Notice at any time. Should we make any material changes, we will post updates on the TTC website prior to the change becoming effective.
9. Who is providing this Privacy Notice?
This Privacy Notice relates to the following entities and their affiliates:
· Totus Tuus Consulting;·
· All entities and accounts managed by the above entities.
10. Who to contact with questions.
If you have any questions, concerns or complaints about this Privacy Notice and the data protection laws, or if you wish to exercise your rights, contact Totus Tuus Consulting at 904-471-6444.