Date of Last Modification: December 4, 2017
Key Commercial Capital, LLC (“Key Commercial Capital”) respects and enforces the privacy expectations of our clients, potential clients, affiliates, and partners who visit our website. This notice discusses what kinds of information we collect about visitors to our website and how this information may be disclosed to third parties who may or may not be affiliated with Key Commercial Capital.
Collection of Information
When you visit our website, certain information is collected automatically. Key Commercial Capital’s main purpose in collecting information from clients and potential clients is for communication and to respond to your questions and requests. However, personal non-public information is required for several of our products and we may ask you to provide them to us. These include:
- Clients completing contracts and related forms, which include a customer’s name, address, social security number, information about the existing retirement accounts a customer holds, and information about a customer’s investment goals;
- Retirement account history, including information about the transactions and balances in a customer’s accounts;
- Financial information to determine availability of financing solutions for you.
- Correspondence, written, telephonic or electronic between a customer and Key Commercial Capital or service providers to Key Commercial Capital.
- If you purchase our services, we will also ask for payment information you wish to be charged.
Disclosure of Client Information
We do not disclose personal information to third parties who are not affiliated with Key Commercial Capital, unless one or more of the following circumstances exists:
- As Authorized – if you request or authorize the disclosure of the information (either directly to your account representative at Key Commercial Capital and to the custodian of any self-directed Individual Retirement Account that you may set up as part of your contract with Key Commercial Capital, or through Key Commercial Capital’s Professional Network).
- As Permitted by Law – for example, sharing information with companies who maintain or service customer accounts for Key Commercial Capital is permitted and is essential for us to provide clients with necessary or useful services with respect to their accounts. Furthermore, we may disclose or report personal information, such as account and transaction data, where we believe in good faith that disclosure is required or permitted under law (e.g., to cooperate with regulators, receivers, or to resolve client disputes).
- Outside Counsel – Key Commercial Capital products/contracts generally include consultation with outside counsel. Your information will be available to the outside counsel in order to facilitate prompt communication and completion of your contract.
- Partners – If you were referred to Key Commercial Capital by one of Key Commercial Capital’s Partners (a Franchisor, a Business/Franchise Broker or Consultant, a Lender, or a Financial Professional), we may provide information to the Partner as to your qualification towards Key Commercial Capital’s products, your status in our processes, and/or other information that is helpful for the parties unless you specifically direct us otherwise.
Security of Client Information
We train our staff to safeguard personal information of our clients, and they are required to use such information for business purposes only. Key Commercial Capital maintains the following policies and procedures regarding privacy with its staff:
- Sensitive information stored electronically in our databases, such as Social Security Numbers, Birth Dates, Credit Card Numbers, etc . . . is encrypted. Access to this information is controlled and stored on secured servers to protect against unauthorized use and access.
- Paper files containing sensitive information are kept in secure areas where access is closely controlled and monitored.
- Staff receives training on the types of information we can and cannot disclose to individuals and/or organizations outside Key Commercial Capital.
Privacy and Security are very important to Key Commercial Capital. Maintaining privacy and security means not disclosing specifics on all our internal practices. Should you have any questions, feel free to contact us.