Terms We Use in This Policy
We, our and us means Darwin Trust Company.
Nonpublic personal information means personally identifiable financial information about you that we collect and that is not available from public sources, such as telephone directories or government records.
An affiliate is a company under common control or ownership. Affiliates can be financial or nonfinancial. Gosselin & Kyriakidis, PC DBA Gosselin Law and DBA Hope Elder Law; Senior Living Homes Sales, LLC DBA Center Square Realty; Senior Living Service Group, LLC; and Senior Living Financial, LLC are affiliates of Darwin Trust Company.
Information We Collect
The information we collect is limited to what we believe is necessary or useful to conduct our business; to understand your financial needs so that we can provide you with the services, financial products and opportunities you want; to protect and administer your records, accounts and funds; to comply with certain laws and regulations; to comply with your requests of us; and to help us design or improve our products and services. We collect this information from the following sources:
- Information we received from you on applications or other forms or in other communications with you, such as your name, address social security or tax identification number, assets, income and debts, financial needs and goals.
- Information we receive from public records and market research such as demographic information.
Information We Share
We do not sell client lists or client information to third parties. We do not share nonpublic personal information about existing clients with nonaffiliated third parties, except as requested by you or as otherwise permitted by law and as described below.
Certain information, such as fiduciary information, is subject to more restrictive information sharing limits by law, agreement and fiduciary duty than other types of information. We strictly adhere to those limits. If you have any questions reading fiduciary information, please contact us.
We may share information with affiliated companies providing financial and related services.
In order to conduct company business, and to offer products or services that may complement your relationship with us, we may share some or all of the information we collect, as described above, with companies that perform services for us or on our behalf, such as vendors we hire to prepare account statements or to provide support for one or more of our products and services.
These companies act on our behalf and are contractually obligated to keep the information we provide them confidential and to use the information ONLY FOR THE PURPOSES AUTHORIZED. We value our client relationship with you and will not disclose your nonpublic personal information to such parties except as authorized by you or otherwise permitted by law.
We may share some or all of the information we collect, as described above, as otherwise authorized or required under applicable law.
We restrict access to nonpublic personal information about you to those employees and agents who need to know that information as part of their job responsibilities. We take appropriate disciplinary measures to enforce employee privacy responsibilities. We maintain physical, electronic and procedural safeguards that comply with the applicable federal standards to safeguard your nonpublic personal information.
Last updated: December 20, 2019
What are cookies
Cookies are small pieces of text sent to your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.
Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.
When you use and access the Service, we may place a number of cookies files in your web browser.
- To enable certain functions of the Service
- To provide analytics
We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:
- Analytics cookies. We may use analytics cookies to track information how the Service is used so that we can make improvements. We may also use analytics cookies to test new advertisements, pages, features or new functionality of the Service to see how our users react to them.
In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on.
What are your choices regarding cookies
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
- For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050
- For the Internet Explorer web browser, please visit this page from Microsoft: http://support.microsoft.com/kb/278835
- For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
- For the Safari web browser, please visit this page from Apple: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
- For any other web browser, please visit your web browser’s official web pages.
Securities and Exchange Disclosure
The Securities and Exchange Commission has adopted a rule to provide a means of direct communications between issuing companies and their beneficial shareholders whose securities are registered in the name of a bank or a bank’s nominees.
Under the rule, you have the right to decide whether you wish us to disclose your name, address and securities positions to companies in which you have invested as well as to those companies in which you may invest in the future. An issuing company would be permitted to use the information for corporate communications purposes only.
Darwin Trust Company does not disclose names, addresses or security positions without client consent.
Customer Information Disclosure
To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account.
What this means to you: When you open an account, we will ask your name, address, date of birth, social security number or tax identification number, and other information (including a copy of a valid government issued form of ID) that will allow us to identify you. This information will be verified to ensure the identity of all persons opening an account.
In certain instances, Darwin Trust Company is required to collect documents to fulfill its legal obligation. Documents provided in connection with your application will be used solely to establish and verify a customer’s identity, and Darwin Trust Company shall have no obligation with respect to the terms of any such document.