Privacy Policy

As required by federal law, Private Asset Management, Inc. (hereinafter referred to as PAM) has adopted policies in order to safeguard the personal information of our clients and their families, businesses or other entities; all of the following also applies to former clients.  This policy was adopted to comply with the Regulation S-P by the Securities and Exchange Commission.

PAM’s relationship with its clients is uniquely personal.  We help our clients with important financial matters relating to investment management of private wealth.  As our client, you entrust us with detailed personal information regarding yourself, your family, your investments, your business, your lifestyle, your taxes, your estate planning and financial planning.  Keeping confidential client information secure is a priority. The Privacy Notice explains the collection, use, retention, disclosure and security of information about you and your family and or business.

How We Gather Information

Since PAM’s mission is providing clients with Investment Advice, we necessarily collect and store or archive detailed information about our customers.  The types of information we necessarily collect include, but are not limited to, names, addresses, phone numbers, social security numbers of family members, EIN numbers for businesses and trusts, detailed personal financial information including income tax status and history, detailed net worth data, asset lists and valuations, insurance and estate planning documents, and other personal and family data.  This information is derived from the following sources:

Client information forms, portfolio appraisals, financial account statements, gain/loss data, income tax returns, personal financial records, financial planning documents, insurance policies and statements, estate planning documents and personal checking/brokerage/bank/ retirement plan/stock option plan statements provided to us by you or your trusted advisors to assist us in understanding your investment needs, risk tolerance, long term objectives and overall financial situation; our analysis of this information, which is generally quite specific and detailed, is necessary to develop a suitable investment management program.

Interviews with you and members of your family, interviews or discussions with various trusted advisors including, but not limited to, your tax preparation professional, attorney, financial planner, insurance advisor, estate planning professional, broker or other trusted advisors.

Information from transactions that we execute on your behalf.
Information received from you, your family or your trusted advisors in written, telephonic or electronic form.

Our Customer Privacy Policy

PAM serves as a fiduciary for our investment management clients and we protect personal information by maintaining physical, electronic and procedural safeguards. We will not sell, share or divulge confidential information pertaining to our clients to any unaffiliated third party except as outlined below. We may disclose any kind of information when we believe it necessary for the conduct of our business or where disclosure is required or permitted by law, certain of the information described above for the purposes outlined below.

Disclosure of Information Required to Conduct Business on Your Behalf

In the normal course of conducting our business acting as a fiduciary on behalf of our clients, we must necessarily share or disclose some data about our clients to custodial organizations (who usually also possess detailed personal information about you as their client), brokerage firms who may be selected to execute transactions on behalf of our clients, clearing agent firms, other service providers and law firms pursuing shareholder class action lawsuits. All of these organizations have their own privacy and customer confidentiality obligations and policies, and many are subject to Regulation S-P. In most cases these are large, national organizations that have sophisticated and disciplined compliance procedures. It is important for you to understand that we would not be able to conduct business on your behalf without disclosing certain limited information regarding you and your account to these unaffiliated parties.

Disclosure of Information with Your Consent

In the normal course of our business, company associates are frequently requested by customers to provide confidential client information including, but not limited to, gain/loss reports, asset cost basis and market value data, etc. to accountants, lawyers, financial planners/advisors or brokers. We are happy to comply with such client requests; however we must request that clients provide written or electronic confirmation of such requests in order to ensure the release of this confidential data does not violate the spirit or letter of Regulation S-P.

Disclosure of Information to Legally Empowered Regulatory Entities

PAM is subject to registration with The Securities and Exchange Commission and state regulatory authorities.  The SEC is empowered to perform certain audit functions to ensure our company complies with laws governing Registered Investment Advisory Firms.   In the course of performing such audit function, these regulatory authorities may request data and information regarding our clients.  We could also be required to provide information about you without your consent, as permitted by law, to respond to a subpoena or court order or in connection with proposed or actual sale, merger or transfer of ownership of our business.

PAM is also subject to an independent audit and as part of that audit certain confidential information may be disclosed to our auditors.  However, such information is kept confidential and not disclosed to the public and is only provided to the extent required by our auditors.

Our Website

Information We Collect Automatically

If you visit our website to browse, read, or download information:
Your web browser automatically sends us (and we may retain) information such as the: Internet domain through which you access the Internet (e.g., yourServiceProvider.com if you use a commercial Internet service provider, or yourSchool.edu if you use an Internet account from your school); Internet Protocol address of the computer you are using; type of browser software and operating system you are using; date and time you access our site; and the Internet address of the site from which you linked directly to our site.

We will use this information as aggregate data to help us maintain this site, e.g., to determine the number of visitors to different sections of our site, to ensure the site is working properly, and to help us make our site more accessible and useful.  We will not use this information to identify individuals, except for site security or law enforcement purposes.
We will not obtain personally-identifying information about you when you visit our site, unless you choose to provide such information.

Security

Please note that electronic communication, particularly email, is not necessarily secure against interception. Please do not send sensitive data (e.g., Social Security, investment account, or credit card numbers) by email or web form.

Cookies

We may use cookies in order to customize this site for return visitors. These cookies are not required for site functionality. Additionally, third-party widgets such as YouTube or Schwab may install cookies depending on their configuration. You are not required to accept any cookies to use this site.

Google Analytics

We use a tool called “Google Analytics” to collect information about use of this site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.  You may also wish to utilize Incognito or Private Browsing mode while viewing the site.