As accountants, we collect nonpublic personal information about our clients, from other accountants, insurance agents and other advisors, as well as from our clients. Such information may include your name, address, telephone number, and personal and family financial information.
It is our policy not to disclose nonpublic personal information that we collect as described above on our clients and former clients to anyone, except as authorized by you or as required by law. In providing financial services to our clients, however, it may be necessary to disclose nonpublic personal information to non-affiliated persons that perform services or functions on our behalf, such as government bodies, your attorney, appraiser, actuary, or loan officer. We may also be obligated to disclose any or all of the nonpublic personal information described above, as permitted by law. For example, we may be obligated under the law to disclose information in response to lawful requests from law enforcement agencies.
We restrict access to nonpublic personal information about you to those Avinna employees and vendors or others, who are subject to our policies, IRS requirements or NCUA rules, whom we determine have a legitimate need to access such information. We maintain security procedures, such as full-disk encryption on all portable computers, for the protection of the personal information of our clients. We also educate our employees about the importance and meaning of, and necessity for, data security and confidentiality.