PRIVACY NOTICE
Last Updated: August 2018
Protecting Your Personal Information is Important
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information.
This privacy notice (“Notice”) is provided by Marquis Wealth Management Group, LLC (referred to herein as “Marquis Wealth Management Group,” “our,” “us,” “we”). This Notice is addressed to any current clients and/or investors of Marquis Wealth Management Group as well as any of our prospective clients or investors (“you,” or “your”) whose personal information Marquis Wealth Management Group collects and controls to conduct its business.
This Notice describes how we collect and use personal information about you during and after your working relationship with us, including on our firm’s website (“Site”). This Notice describes the basis upon which and for what purposes we process your personal information, as well as your privacy rights under certain privacy laws including, where applicable, under General Data Protection Regulation (“GDPR”) and applicable US privacy laws, and how we protect your personal information.
We know that you are concerned with how we deal with your personal information. Maintaining your privacy is important to us and we hold ourselves to the highest standards in its safekeeping and use. We have developed policies designed to protect the confidentiality of your personal information, while allowing the needs of clients and investors to be served.
Sources and Categories of Personal Information We May Collect From You
When you establish a relationship with us, you are requested to furnish personal and financial information to assist in assessing your financial objectives and goals. The information you share with us is private and confidential, and we are committed to protecting your privacy. In addition to the information collected during the course of our relationship we may also collect a variety of nonpublic personal information from other sources.
We collect personal information that may directly, or indirectly, identify you, including non-public personal information, from the following sources: information we receive from you on applications, client questionnaires and other forms; information about your investment transactions from financial service institutions, accountants, lawyers, mortgage brokers and others.
The specific types of personal information we collect and share depend on or service you have with us. This information can include:
- personal information such as name, telephone, address, date of birth, social security number, government identification, and marital status;
- digital footprint data such as e-mail;
- biographical data such as age and gender;
- employment data such as social security number or national insurance number, salary information, job position, and tax information;
- financial Information such as bank information, salary information, pension, etc.
What Personal Information Do We Collect When You Visit our Site?
When you visit our Site, we collect information from you when you register or fill out a form. We are the sole owners of the information collected on this Site. For more information on what information we collect on our Site, please see the section, “Additional Information about Our Site” and corresponding Appendix below.
We will not sell or share this information with anyone unless otherwise specified. For more information, please see the section, “Disclosure of your Personal Information to Third Parties.”
How is Your Personal Information Used?
We will only use your Personal Information with the purpose to provide you with our investment services. In managing your investment for you, we will use your Personal Information to:
- monitor, audit, evaluate and otherwise continue to administer our services and conduct business processing functions including the provision of your Personal Information to our contractors, service providers or other third parties;
- communicate with you and respond to your inquiries;
- protect against, identify and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other unlawful activity, claims and liabilities;
- conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms;
- and/or for other purposes required or authorized by law, including other purposes for which you have provided your consent.
Where required by applicable law, we obtain consent to process Personal Information. In the event that we use Personal Information we collect for other purposes not identified above where direct client consent is required under applicable rules, laws and/or regulations we will provide specific notice at the time we collect such Personal Information.
Lawful Basis for Processing
Marquis Wealth Management Group may have one or more of the following lawful bases to
process your personal information:
- Consent: your freely, informed, and voluntary consent to process your personal information in connection to our investment services.
- Contract: processing your personal information is necessary in order to fulfill a contract.
- Legal Obligation: processing is necessary to comply with applicable rules, laws, and regulations.
- Legitimate Interests: processing is necessary to the legitimate interests of our firm and/or a third party.
Disclosure of Your Personal Information to Third Parties
All financial companies need to share client’s personal information to run their everyday business. It is the policy of Marquis Wealth Management Group to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide services in furtherance of the client’s engagement of Marquis Wealth Management Group.
In that regard, Marquis Wealth Management Group may disclose the client’s information:
- to individuals and/or entities not affiliated with Marquis Wealth Management Group, including, but not limited to the client’s other professional advisors and/or certain service providers that may be recommended or engaged by Marquis Wealth Management Group in furtherance of the client’s engagement of Marquis Wealth Management Group (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, record keeper, proxy management service provider, etc.);
- required to do so by judicial or regulatory process; or
- otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations.
The disclosure of information contained in any document completed by the client for processing and/or transmittal by Marquis Wealth Management Group to facilitate the commencement/continuation/termination of a business relationship between the client and/or between Marquis Wealth Management Group and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, record keeper, insurance company, etc.), including, but not limited to, information contained in any document completed and/or executed by the client in furtherance of the client’s engagement of Marquis Wealth Management Group (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding non-affiliated third party service provider.
We limit access to nonpublic personal information to only those employees who have a business or professional reason for knowing it and who have signed a copy of Marquis Wealth Management Group’s Privacy Policy to have access to client information. Employees violating Marquis Wealth Management Group’s Privacy Policy will be subject to Marquis Wealth Management Group’s disciplinary process. Marquis Wealth Management Group limits access to nonaffiliated third parties as permitted by law. Additionally, whenever Marquis Wealth Management Group hires other organizations to provide services to Marquis Wealth Management Group’s clients, Marquis Wealth Management Group will require them to sign confidentiality agreements and/or the Privacy Policy.
We do not provide your personal information to mailing list vendors or solicitors for any purpose. Disclosure of any nonpublic personal information about our former clients is handled in the same manner as for our current clients.
In the section below pursuant to U.S. Federal Laws, we list the reasons financial companies can share their customers’ personal information; the reasons Marquis Wealth Management Group, LLC chooses to share and whether you can limit this sharing.
| Reasons we can share your Personal Information | Does Marquis Wealth Management Group, LLC share? | Can you limit sharing? |
| For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations | Yes | No |
| For our marketing purposes – to offer our services to you | No | N/A |
| For joint marketing with other financial companies | No | We don’t share |
| For our affiliates’ everyday business purposes – information about your transactions and experiences | No | We don’t share |
| For our affiliates’ everyday business purposes | N/A | N/A |
| For our affiliates to market to you | N/A | N/A |
| For non-affiliates to market to you | N/A | N/A |
Limits on Sharing
To the extent U.S. Federal laws apply to your personal information, you have the right to limit only:
- sharing for affiliates’ everyday business purposes;
- affiliates from using your information to market to you; and
- sharing for non-affiliates to market to you.
U.S. state laws and individual companies may give you additional rights to limit sharing.
Individual Rights
To the extent permitted by the applicable law of your jurisdiction, in relation to your personal
information, you may request:
- to have your personal information corrected, for example, if it is incomplete or incorrect;
- to opt out of receiving marketing communications at any time;
- the right to file a complaint with an applicable government regulator such as a Data Protection Authority.
In addition to the foregoing, if you are located in the European Economic Area (“EEA”), to the extent permitted by applicable law, in relation to your personal information, you may request:
- to access the personal information held by us about you;
- the right to restrict or object to the processing of your personal information, or request that your personal information is erased;
- the right to receive a copy of the personal information which you have provided to our firm, in a structured, commonly used and machine-readable format (known as “data portability”);
- have a copy of the personal information we hold about you provided to you or another controller where technically feasible;
- where you have provided personal information voluntarily, or otherwise consented to its use, the right to withdraw your consent.
To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to your information.
Will Your Personal Information be kept Accurate, Complete and Up to Date?
We will endeavor to ensure your personal information is kept accurate, complete, up to date and relevant. Please let us know if any of your details change. If you feel your personal information is not accurate, complete or up to date, please notify us and we will take reasonable steps to ensure it is corrected. You can contact us using the details listed below.
Is Your Personal Information Secure?
Marquis Wealth Management Group continually updates and improves security standards and procedures to guard against anyone gaining unauthorized access to your Information, including through the Internet.
We restrict access to your nonpublic personal information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your nonpublic personal information.
Site Security
As our Site is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
Links to Third-Party Websites. As a convenience to you, Marquis Wealth Management Group may provide hyperlinks to websites operated by third parties. When you select these hyperlinks you will be leaving our Site. Marquis Wealth Management Group has no control over third party websites, their content, or security. Accordingly, when you access these third party websites it is at your own risk. We encourage you to read the associated privacy policies by such third party websites to learn more about their data privacy management practices. Marquis Wealth Management Group may, in its sole discretion, block links to our Site and Content without prior notice.
Marquis Wealth Management Group.
Retention and Processing of Personal Information
To the extent permitted by applicable law, we retain your personal information for the period necessary to serve the purposes for which we obtained it. We may also retain your personal information beyond such period in accordance with applicable laws, regulations, or another lawful basis, including but not limited to, compliance with our contractual obligations, legal obligations, regulatory obligations, legal claims, or another legitimate interest.
Data Transfers
We may transfer the personal information we obtain about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. To the extent required by applicable law, when we transfer your information to recipients in other countries (such as the United States, United Kingdom, Ireland or Cayman Islands), we will protect that information as described in this Notice.
If you are located in the European Economic Area (“EEA”), we will comply with applicable legal requirements regarding the provision of appropriate safeguards for the transfer of personal information to recipients in countries for which the European Commission has not issued an adequacy decision.
