Padden Cooper, LLC Privacy Policy

PADDEN COOPER PRIVACY DISCLOSURE (Revised May 2011)

Protecting your privacy is important to Padden Cooper and to our employees. We want you to understand what information we collect and how we use it. In order to provide our clients with a broad range of financial products and services as effectively and conveniently as possible, we use technology to manage and maintain customer information. Our privacy policy serves as a standard for all Padden Cooper employees for collection, use, retention and security of nonpublic personal information. This disclosure applies to all accounts that are established for personal, family,  household, business, or commercial purposes.

WHAT INFORMATION WE COLLECT

We may collect "nonpublic personal information" about you from the following sources:

• Information we receive from you on applications, government documents, tax returns, or other account forms such as your name, address, social security number, assets, liabilities, and income;
• Information about your transactions with us, our affiliates or others such as your account balances, and payment history; and
• Information we receive from third parties such as consumer reporting agencies, W-2’s, 1099’s, and other tax and financial information.

If you have established a brokerage account, we will collect information about your investments and transactions with others or with us such as your account balances and investment transactions with other parties.

WHAT INFORMATION WE DISCLOSE TO OUR SUBSIDIARIES OR AFFILIATES

We may share information about our experiences or transactions with you or your account (such as your name, address, etc…) or we may share other information you have authorized us to share .

WHAT INFORMATION WE DISCLOSE TO NONAFFILIATED THIRD PARTIES

We do not disclose any nonpublic personal information about you to any third parties, except as permitted by law.

We may disclose nonpublic personal information about you described above to "nonaffiliated third parties" (i.e., third parties that are not members of our corporate family) only as permitted by law. For example, we may disclose nonpublic personal information about you to such third parties -

• When you have given your consent to do so;
• When we complete your transactions, such as paying your checks, processing your online bill payment transactions or processing your trade requests;
• When we share information with consumer reporting agencies;
• When we verify account status for merchants you want to pay by check;
• When we suspect fraud or for risk management purposes;
• When we are required by a federal, state, or local law or regulation; or
• When we receive a subpoena or are ordered by a court to do so.

We may also disclose, consistent with applicable law, all of the information we collect, as described above, to nonaffiliated third parties that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements, but only when they agree to uphold and maintain our privacy standards when handling a customer's nonpublic personal information and to use it only to perform the services for which we hired them.

We do not provide nonpublic personal information to financial institutions or to nonaffiliated third parties to perform telemarketing services.

FORMER CLIENTS

If you decide to move your services or become an inactive client, we will continue to treat and safeguard your information as described in this notice.

HOW WE PROTECT YOUR INFORMATION

We take steps to safeguard customer information. We restrict access to your personal and account information to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

HOW TO CORRECT ANY ERRORS

If you ever find any errors with your account or returns, please call us at 609-953-1400. It is our policy to investigate and correct errors in a timely manner that are brought to our attention.