Information That We Collect
We collect personal information about you from a variety of sources to help us serve your financial needs, offer products and services and satisfy our legal and regulatory requirements.
• We receive information provided by you or on your behalf, to us, or to our registered representatives, agents or financial professionals (financial professionals). This information may be provided on forms and applications as well as through personal discussions. For example, this information may include: social security number, name, address, birth date, assets, income, beneficiary, employment, health and other financial information.
• We acquire information regarding your account and transaction history, including products and services, balances and payment history, and information as to your credit worthiness and history from our affiliates, unaffiliated service companies and consumer reporting agencies.
• We receive information from other unaffiliated third parties, including employers, associations, benefit plan sponsors, financial aggregators and other institutions and individuals, including from institutions where you have had a relationship.
Information We May Disclose
We do not sell or disclose your non-public personal information to non-affiliated third-party marketing companies.
We may disclose information that we collect as required to conduct our business and as permitted or required by law. We may share information about you with unaffiliated financial institutions such as our clearing firm, broker-dealers, investment advisors, third party administrators, plan sponsors, mutual funds, insurance companies or agencies, solicitors and other third parties who assist us in providing account or related services to you. We share information with non-financial companies that provide services to us such as consumer reporting agencies and consulting firms.
We may share your information with auditors, regulators, non-regulatory industry licensing/registration entities and law enforcement organizations, including in response to court orders, subpoenas or inquiries, or as permitted or required by law.
You are not able to opt out of our sharing your information for the purposes described in this section. See State Information on page 2.
Sharing with an Unaffiliated Broker-Dealer—Your Right to Opt-Out
Fulcrum’s advisory representatives are also registered with Cetera Advisors LLC (“Cetera”), an unaffiliated broker-dealer and investment adviser. Cetera requires that Fulcrum representatives share information about their advisory activities away from Cetera. This requirement satisfies rules promulgated by FINRA, a self-regulatory organization of which Cetera is a member. This requirement means that we will share information about you, your accounts, your transactions, your profile with Cetera, even though they are not providing brokerage or advisory services to you. Cetera is a regulated entity and is required to keep your information confidential and to safeguard it appropriately. They are not permitted to sell your information or use the data they obtain from us to market to you. You are permitted to opt-out of this sharing, but if you do so, we will not be able to provide advisory services to you. If you do not want to allow us to share your information with Cetera, please call (425) 800-8275.
We have implemented security standards and processes as well as physical, electronic and procedural safeguards—including training and confidentiality agreements—designed to protect your information.
Policy Relating to Former Customers
If we change this policy materially, we will notify you at least 30 days before the changes go into effect.