privacySmith, Brown & Groover, Inc. (“SBG”) has been committed to protecting the privacy and security of the information that our clients share with us since we started our business in Middle Georgia over 75 years ago. We have always appreciated our client’s trust in providing us with confidential information and we believe we have honored that trust by handling such information in a careful and discreet manner. In response to the passing of the Gramm-Leach-Bliley Act by Congress, the U.S Securities and Exchange Commission adopted Regulation S-P under Section 504 of the Act. This requires us to provide you with a written notice of our policies and practices related to private, financial information.

Information that we collect and maintain:
We collect and retain nonpublic personal information about you that we are required to solicit from you as broker/dealers in accordance with SEC, FINRA and IRS regulations. This includes your name and address, your age or date of birth, and your tax identification number. We are also required to make reasonable efforts to obtain information about your occupation and employer, whether your are associated with another FINRA firm, whether you are an officer or director of a public corporation, and information about your income, tax status and net worth. We may also ask about your financial goals and about your children. The purpose of this information is to accurately establish, identify and service your account(s) and to evaluate your suitability when providing investment advice to you. We collect medical data for insurance or annuity applications as required by the insurance companies, but we do not enter this information into any of our computerized records. We do not collect any information collected through the use of Internet data capture devices when you access our web site, although other brokers or sponsors that hold account assets for you may do so. They are also required to notify you of such usage through their own privacy notices.

Information that we share:
We do not disclose or share any nonpublic personal information about our current or former clients to any party, except as permitted by law. Examples of how we share information include (1) processing account transactions that you have requested or authorized; (2) complying with a court, regulatory or similar legal order or proceeding; (3) verifying unique information to prevent fraud; (4) facilitating mailings of mutual fund prospectuses or stock related reports you have requested; or (5) providing your accountant or attorney with copies of statements or confirmations for tax or estate related matters. In all cases, these third parties are not permitted to use, release or transfer any information to other parties for their own purposes. We do not provide information to credit or banking institutions without the client’s written permission.

Maintaining account information:
We continually strive to maintain complete and accurate information about you and your accounts. If you ever believe our records contain inaccurate or incomplete information, we ask that you please contact us immediately and we will correct any inaccuracies as quickly as possible.

Account information security safeguards:
SBG does not provide any data, mailing or similar information service with information about its customers, and the representatives and staff of SBG are likewise prohibited from disseminating such information. We use procedures and controls that are designed to protect against unauthorized access to your accounts. We use a bonded document destruction service to dispose of older records after satisfying compliance with the records retention guidelines of our regulators.