Your Privacy
Is Important to HighTower
Privacy Policy Notice for HighTower
We have adopted this policy with recognition that protecting the privacy and security of the personal
information we obtain about our customers is an important responsibility. We also know that you expect
us to service you in an accurate and efficient manner. To do so, we must collect and maintain certain
personal information about you. We want you to know what information we collect and how we use and
safeguard that information. This information is provided to you in accordance with the regulations and
rules we are governed by, and we are required to provide this Privacy Policy Notice to all new and
existing customers.
INFORMATION WE COLLECT FROM YOU
We collect certain nonpublic personal identifying information about you (such as your name,
address, social security number, date of birth, income, assets, investment preferences, etc.) from
information that you provide on applications or other forms as well as communications
(electronic, telephone, written or in person) with you or your authorized representatives (such as
your attorney, accountant, etc.). We also collect information about your investment and
insurance accounts and transactions (such as purchases, sales, account balances, inquiries, etc.)
and information to process transactions or to conduct online transactions. If you apply for life
insurance, we may receive information on your health or habits.
INFORMATION FROM THIRD PARTIES
If needed, we may also obtain information from third parties. For example, we may obtain
information from you to evaluate your application or verify your identity. This may include:
personal and credit information from consumer reporting agencies; information from other
companies about contracts or accounts transferred to us.
MEDICAL INFORMATION
We may collect medical information only to submit to an insurance company to underwrite life
insurance or annuity products. We get written consent from you before we obtain this
information from third parties. We do not share medical information for marketing purposes.
We only share it within strict limits as allowed or required by law.
INFORMATION WE SHARE
We share information only in a limited way to conduct business and provide service to
customers, or as required by law. The law allows us to share the personal information listed
above with our affiliated firms, also known as our family of companies. We share this
information to carry out routine business activities.
WHAT INFORMATION WE DISCLOSE
We do not disclose the nonpublic personal information we collect about you to anyone except:
(i) in furtherance of our business relationship with them and then only to those persons necessary to effect the transactions and provide the services they provide (such as broker-dealers,
custodians, independent managers, etc.); (ii) to persons assessing our compliance with industry
standards (e.g., regulators, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise
provided by law. No nonpublic personal information is provided to outside firms for marketing
purposes.
We are permitted by law to disclose the nonpublic personal information about you to
governmental agencies and other third parties in certain circumstances (such as third parties that
perform administrative services on our behalf). These third parties are prohibited from using or
sharing the information for any other purpose, and they are required by contract to maintain the
confidentiality of your information. If you decide at some point to either terminate our services
or become an inactive customer, we will continue to adhere to our privacy policy, as may be
amended from time to time.
SAFEGUARDING OF YOUR INFORMATION
We restrict access to your nonpublic personal information to those employees who need to know
that information to service your account. We train our employees to keep your information safe
and confidential. We maintain physical, electronic and procedural safeguards that comply with
applicable federal or state standards.
CHANGES TO OUR PRIVACY POLICY
Our policy about obtaining and disclosing information may change from time to time. We will
provide you notice of any change we make regarding the sharing of your nonpublic personal
information before we implement the change. You will also receive a copy of this notice once
every 12 months.
WITHIN OUR FAMILY OF COMPANIES
All procedures in this Privacy Policy Notice apply to our family of companies including:
HighTower Holding, LLC; HighTower Securities, LLC; and HighTower Advisors, LLC.
FOR QUESTIONS, PLEASE CONTACT US
ATTN: Chief Compliance Officer
HighTower
525 West Monroe Street, Suite 2300
Chicago, IL 60661
312.962.3820
Compliance@HighTowerAdvisors.com
HighTower may obtain personal information about you if you provide it in the course of using our website, www.hightoweradvisors.com (“the Website”). Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.
This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the term “HighTower” refers to HighTower Advisors LLC and its affiliates worldwide. This statement applies only to information collected at the Website and may not apply to personal information collected by our company offline. We will collect information only from people over the age of 18, who are residents of the US.
The Sources of Information
The Website collects personal information from our visitors only on a voluntary basis. We do not require this information for visitors to obtain access to the Website. The personal information we collect about you comes from information you submit to the Website. A separate privacy statement covering our practices with respect to our investors’ financial information will be provided in another document delivered to investors at the appropriate time.
The Information We Routinely Collect
The Website collects your name, address and other contact details.
Our Use of Your Personal Information
We may use your personal information to contact you about our services.
Disclosures of Your Personal Information within HighTower
In order to best inform you about our services, more than one entity within HighTower may be given, or given access to, your personal information.
Disclosures of Your Personal Information to Third Parties
HighTower does not disclose your personal information to third parties, except as described in this policy. Non-affiliated companies that assist HighTower in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that HighTower dictates. The Website may need to disclose your information to lenders in order to secure financing. The Website could merge with or be acquired by another business entity or some or all of its assets could be acquired. If such a combination or acquisition occurs, your personal information will necessarily be a business asset that is acquired in the transaction.
Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; for instance, when responding to a subpoena or similar legal process, to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities or with organizations such as exchanges and clearinghouses.
Information Security: How We Protect Your Privacy
HighTower is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized HighTower employees or agents and, as described above in Disclosures of Your Personal Information to Third Parties, our service providers are held to stringent standards of privacy. We also maintain appropriate physical, electronic and procedural safeguards to help protect the information against loss, misuse, damage or modification and unauthorized access or disclosure.
Privacy and the Internet
The following additional information will be of interest to you if you access HighTower products or services through one or more HighTower web sites:
"Cookies" are small text files consisting of information stored by your Web browser. This information is used for administrative purposes and to improve your experience with our Web sites. For example, this information helps authenticate you (i.e. verify that you are who you say you are), an essential component of site security. Cookies also make it easier for you to navigate a HighTower web site by, among other things, "remembering" your identity so that you do not have to input your password multiple times as you move between pages or services. You can set your Web browser to inform you when cookies are set, or to prevent cookies from being set. However, if you decline to use cookies, you may experience reduced functionality, and declining to use authentication related cookies will prevent you from using the Web site altogether.
"Clickstream" or similar data (e.g. information regarding which of our Web pages you access, the frequency of such access and your product and service preferences) may be collected and shared internally within HighTower in order to assess the usage, value and performance of our online products and services and, if you are a HighTower Advisors client, to suggest products or service offerings that may be of interest to you.
Other Privacy Policies or Statements; Changes to Policy
This policy provides a general statement of the ways in which HighTower protects your personal information. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our Web site. This version of the Policy is effective May 1, 2008.
HighTower may occasionally contact you by post, telephone, electronic mail, facsimile, etc., with details of products and services that we believe may be of interest to you. If you do not wish to be contacted in this way, if you wish to exercise your rights of correction and access, or if you require further information regarding our privacy policies and practices in the above-referenced regions, please contact: HighTower Advisors, LLC