The directors, management, and staff of Surplus Asset Management are
concerned about and respect the privacy of our customers' financial
information. We understand that our customers furnish private information
to our companies in the course of daily business, and we are committed to
treating such information responsibly. We know that our customers expect
privacy and security for their personal and financial affairs.
We will take steps to safeguard private information that has been
entrusted to us by our customers. When we do use information, it is to
help serve you better. Your information helps us appreciate all the
business you have with our companies and identify affordable products and
disclosure outlines our practice regarding personally identifiable
financial information (or "nonpublic personal information") for
consumers, those consumers who become our customers, and our former
customers. This disclosure is made on behalf of (but not limited to)
Surplus Asset Management, LLC.
USE OF INFORMATION
We use personal information in ways that are compatible with the purposes
for which we originally requested it. For example, we will use the
information you give us to process your requests and transactions, to
provide you with additional information about products and services or to
evaluate your business needs. We collect and use personal information to
administer our business and deliver quality service to you. This may
include advising you about our products or services, those of our
affiliates, those of our business partners and other opportunities that we
believe may interest you.
CUSTOMER PRIVACY BILL OF RIGHTS
Surplus Asset Management Employees
At Surplus Asset Management, any employee access to customer information
is authorized for business purposes only and is based on the sensitivity
of the information and our employees' or agents' need to know. We remind
employees regularly of their obligations for using customer information.
Disregard of these obligations will result in disciplinary action,
including termination in appropriate cases.
At Surplus Asset Management, we collect, retain, and use information about
you for the purpose of serving your business needs and administering our
account relationships. We collect information we receive from you on our
registration form and other forms like surveys and questionnaires (for
example, requests for information about products and services). We also
collect (i) information about your transactions with our affiliates,
others or us and (ii) information we receive from consumer reporting
The foregoing information about both current and former customers may be
shared with the following categories of Surplus Asset Management companies
and unaffiliated third parties:
Sharing Within Surplus Asset Management's Family of Companies
To the extent permitted, this information may be shared among Surplus
Asset Management's family of companies (for example, a bank, an insurance
company, or a broker-dealer) in order that we can provide products and
services appropriate to your needs and circumstances. (For more
information about information sharing options, see the "Your
Choices" section below.)
Sharing with Surplus Asset Management's Service Providers/Joint
From time to time, we may use outside companies to perform services for
us, to assist in marketing our own products and services or products or
services we market jointly with other financial institutions, and to
perform market research. In order to complete these tasks, we may provide
our service providers with information we collect about you. We require
our service providers to comply with our standards regarding security and
confidentiality, and permit them to only use your information for purposes
authorized by us.
Surplus Asset Management may also enter into joint marketing agreements
with selected companies. We may disclose all of the information we
collect, as described above, to these selected financial institutions in
order to assist us in providing quality products and services to you.
We require these companies to keep your nonpublic personal information
confidential, and permit them to only use your information for purposes
authorized by us.
You should also be aware that there may be occasions where we are legally
required to disclose information about you, such as in response to a
subpoena, to prevent fraud, or to comply with a legally permitted inquiry
by a governmental agency or federal regulator. We do not disclose any
nonpublic personal information about you to any third parties, except as
permitted by law.
We have established and continually maintain security standards and
procedures to help us protect you from unauthorized access to confidential
nonpublic personal information that Surplus Asset Management maintains
about you, including through the Internet.
ACCURACY AND RIGHT TO CORRECT
Your Account Information
We continually strive to maintain complete and accurate information about
you and your accounts. Should you ever believe that our records contain
inaccurate or incomplete information about you, please notify us. We will
investigate your concerns and correct any inaccuracies.
Information Reported to Consumer Reporting Agencies
Under the Fair Credit Reporting Act, you have the right to notify us if
you believe we have reported inaccurate information about your account to
any consumer-reporting agency. Such notices should be sent in writing and
include your complete name, current address, social security number,
telephone number, account number, type of account, specific item of
dispute and the reason why you believe the information reported is in
error. Send your notice to Surplus Asset Management, LLC., PO Box 217,
Bristol, CT 06011. We will investigate your concerns and correct any
inaccuracies and confirm our actions to you.
Information Shared Within Surplus Asset Management's Family of
Responsible use of information benefits our customers both by protecting
you and enabling us to provide more relevant and customized products and
services to meet your business needs. At Surplus Asset Management, we
share customer transaction and experience information within our family of
companies through a central information system.
We are permitted to share other customer information within our family of
companies. This can help us improve the type and selection of products and
services we provide. If you do not want us to share this other information
(except transaction and experience history) among Surplus Asset
Management's family of companies, complete the form provided in this
The registration and profile update forms allow for options to identify
you as a participant in information sharing. We will process your request
as soon as possible after we receive it.