Our commitment to your privacy: Empire Asset Management Company and Empire Financial Management Company ("Empire") has a policy of protecting the confidentiality and security of information Empire collects about its customers. Empire will not share non-public personal Information about you ("Information") with third parties without your consent, except for the specific purposes described below. This notice describes the Information Empire may gather and the circumstances under which Empire may share it.

Collection of Information: Empire collects and uses the Information it receives to provide quality services to you. Such services include maintaining your accounts with the firm and processing securities transactions at your direction. Empire obtains most of the Information it requires directly from you at the time of account establishment - whether in person, by telephone or electronically. Empire may verify this Information or receive additional Information, including creditworthiness or credit history, from other financial institutions or service providers with whom you may have authorized to provide such Information and/or consumer reporting agencies, verification services or public sources. This Information may relate to your finances, employment, avocations or other personal characteristics, as well as interactions with or through Empire or others. In accordance with federal law, the firm may use any information it receives to verify your identity.

Disclosure of Information: Empire may not disclose Information about you to affiliates or nonaffiliated third parties except as permitted by law, as specifically consented by you, and to the following;

  • To Empire's clearing firm, RBC Clearing & Custody a division of RBC Capital Markets, LLC, its attorneys, accountants, auditors, administrators or other service providers;
  • To respond to a subpoena or court order, judicial process or governmental or regulatory inquiry (including but not limited to, anti money laundering inquires);
  • In connection with a proposed or actual sale, merger, or transfer of all or a portion of Empire's business;
  • To protect or defend against fraud, unauthorized or violative transactions (such as money laundering violations, anti terrorist due diligence), law suits, claims or other liabilities.

Empire does not make disclosures of Information to other companies who may want to sell their products or services to you.

To Whom This Policy Applies: This Privacy Policy applies to Empire's customers.

Opt Out Provision: Please be advised that you have a right to "opt out" of the information sharing as set forth above however, the firm will be unable to establish an account for you as the sharing that occurs is necessary to establish and maintain your account through our clearing firm, RBC Clearing & Custody a division of RBC Capital Markets, LLC. Further, all other information sharing in which we participate is required by the firm's regulators (FINRA and the U.S. Securities and Exchange Commission) and/or the federal/state judicial system. Additionally, the firm reserves its right to share appropriate personal information about you with our attorneys, accountants, auditors and service providers in order to effectively discharge its obligations with federal securities laws and other securities regulations.

Protection of Information: Empire maintains physical, electronic and procedural safeguards that comply with federal standards to protect customer Information. Empire restricts access to the personal and account Information of customers to those employees who are required to possess that Information to fulfill their job responsibilities.

Access to and Correction of Information: If you desire to review any file Empire may maintain regarding your Information, please contact your broker. If you or your broker notifies Empire that any Information is incorrect, Empire will review it. If Empire agrees, Empire will correct its records. If Empire does not agree, you may submit a statement of dispute, which Empire will include in future disclosures of the disputed Information. Information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available.

Further Information: Empire reserves the right to change this Privacy Policy. The examples contained within this Privacy Policy are illustrations and they are not intended to be exclusive. This notice complies with Federal law and SEC re gulations regarding privacy. You may have additional rights under other foreign or domestic laws that may apply to you.