GENESEE VALLEY TRUST COMPANY
Genesee Valley Trust Company (“GVT”) recognizes and respects the expectation of its clients that personal financial information will be maintained in a private and confidential manner, and has adopted the following policy in its effort to safeguard such information.
MAINTENCE OF ACCURATE INFORMATION: GVT has established policies and procedures designed to keep client information accurate, current and complete. To assist us in this effort, however, we request that you notify us if you become aware of any information in our records which you believe to be inaccurate.
LIMITED EMPLOYEE ACCESS/SECURITY: GVT restricts access to non-public personal information about its clients to those employees who need such information to provide services to clients, and all employees are informed of the importance of maintaining the confidentiality of such information. In addition, GVT maintains physical, electronic and procedural safeguards to prevent unauthorized access to and disclosure of our clients’ non-public personal information. For example, our portfolio management web site uses encryption technology to maintain the security of client portfolios and other non-public personal information.
COLLECTION OF NON-PUBLIC PERSONAL INFORMATION: GVT limits its collection of client information to what it believes is necessary or useful to conduct our business and to provide services to our clients. GVT collects the following categories of non-public personal information about its clients: information we receive from you; information about your transactions with us and with non-affiliated third parties with whom we have a business relationship; and information we receive from a consumer reporting agency.
DISCLOSURE OF NON-PUBLIC PERSONAL INFORMATION: GVT limits its disclosure of non-public personal information to those circumstances where it is beneficial to the client or is otherwise required. GVT may disclose non-public personal information it collects to non-affiliated third parties under the following circumstances:
To comply with applicable laws and regulations
To protect GVT from fraud, or in the event of litigation
Upon written consent of or request from a client
To complete a transaction initiated by a client
Where the non-affiliated third party assists in providing a product or service
In the normal course of business
Where GVT discloses non-public personal information to a non-affiliated third party with which we have a business relationship, we will require that the third party protect the confidentiality of such information.
OPT-OUT RIGHT OF CLIENT: Clients who prefer that we not disclose non-public personal information to non-affiliated third parties may “opt-out” and direct us not to make such disclosures. If you wish to “opt-out”, you may do so by contacting in writing our Operations Manager.
Your right to opt-out does not apply when disclosure:
- is necessary to effect, administer or enforce a transaction requested or authorized by you;
- is necessary to service or process a product or service requested or authorized by you;
- is necessary to maintain or service your account;
- is made pursuant to your consent or at your direction;
- is necessary to protect the security or confidentiality of your records;
- is necessary to protect against fraud, unauthorized transaction claim or other liability;
- is made to persons with a legal interest in such information or acting as a fiduciary;
- is permitted or required by regulation, law enforcement or a state insurance authority; or
- is to a consumer-reporting agency in accordance with the Fair Credit Reporting Act.
CONTACT INFORMATION: GVT is committed to protecting client privacy. If you have any questions, complaints or concerns, please direct them to:
Name: Kurt E. Rosen, Operations Manager
Address: 1221 Pittsford-Victor Rd.
Pittsford, NY 14534
Phone: (585) 586-6900
Facsimile: (585) 586-5341
E-mail address: email@example.com