Revised as
of August 2002
This Policy is issued on behalf of
Summit Advisors, Inc. and Jack Pratt. For more information on us, please see our
Corporate Overview.
We are always aware that when you are a
client, you entrust us with more than your information. You also share personal
and financial information. We take very seriously the obligation to keep that
information confidential and private. SAI is committed to maintaining the
privacy of the information you share with us. We want to assure you that
information about shared with us is not sold to any third party. In the
following statement, we describe what information is gathered from
www.jack-pratt.com and from certain other sources and how we use it. If you have
any questions, please call 281-980-1900 and we will be happy to assist you.
Information we gather from our
customers.
SAI collects nonpublic personal information about you from applications or other
forms you complete and from your transactions with us or our affiliates. The
term "personal information" includes information such as your name, address,
telephone number, email address, Social Security number or other national
identification number, account number, income, assets information, account
balance, trade secrets, strategic plans, and investment history.
Information we gather on this web
site.
We gather two types of information on this site: personal information about you
and general information about how the site is being used.
We gather personal information in phone
calls, in person and when you fill out a questionnaire forms. We also collect
general web site tracking information, such as which pages are viewed at which
times, automatically through our web server software.
What we do with the information we
gather.
We do not disclose information about you, or our former customers, to our
affiliates or to service providers or other third parties except on the limited
basis permitted by law. For example, we use this information to administer your
accounts with us through such activities as sending you confirmations, annual
reports, feedback forms and assessments. Your personal information also lets us
know how to contact you so that we may answer your question or respond to your
request. Your Social Security number and account number help us protect your
privacy; they help us verify that you are authorized to access the account you
are requesting to view. To serve you better, we may combine information you give
us through this web site or through other communication channels.
The general web site tracking
information is used to give us a summary view of how our web site is used.
Currently we do not track individual users; but we may implement the capacity to
do so in the future. In any case, we currently analyze the data, and will
analyze the data in the future, only to determine how to make the web site
better and more useful. This information is and will be strictly for our
internal use.
We may conduct surveys regarding our
services, including the operation of our web site. The information you provide
is used only on an aggregated basis and is analyzed only to improve our services
and for company management and planning purposes. You will not receive
communications as a result of your participation in one of our surveys if you
notify us not to contact you
Our policy on sharing site
information with third parties.
Your privacy is one of our biggest priorities. Information about you and any
users of www.jack-pratt.com is not sold or rented to any third party. We do not
trade such information with any third party. Even within, only people involved
with servicing your accounts have access to your personal information.
We do reserve the right to disclose or
report personal information in limited circumstances where we believe in good
faith that disclosure is required under law, to cooperate with regulators or law
enforcement authorities, and to protect our rights or property. We reserve the
right to use your email or other address to send you important information
relating to your account, including regulatory communications.
How we protect your information.
To ensure a high level of confidentiality and security, SAI maintains physical,
electronic and procedural safeguards that meet or exceed federal standards.
When we share personal information with
our service providers, we expect them to treat that information with strict
confidentiality and to retain your personal information no longer than is
necessary to provide the service or information.
We expect our employees with access to
confidential customer information not to use or disclose the information except
for business purposes. Personal information about you is normally used only by
those employees who need to know that information to provide our products or
services to you. All employees are expected to safeguard such information and
employees who violate these obligations will be subject to our normal
disciplinary process.
Special security measures apply to your
communications with us on this web site. Detailed information is available at
our
Web Security & Privacy FAQs.
Internally, we employ encryption technologies, user authentication systems
(e.g., passwords and personal identification numbers) and access control
mechanisms to secure access to our computer systems and files. We employ
firewalls for our Internet-based systems.
How you can correct and update
personal information.
If you need to update or correct any personal information, you may contact us at
281.980.1900.
How you can block access to your
account information from our web site.
We hope that you'll benefit from having 24-hour Internet access to your SAI
account. However, we understand that you may prefer not to participate in this
service. If for any reason you wish to block access to your account information
from this web site, simply call 281-980-1900 and ask that your account be
blocked from the web site.
Communications with us.
Jack Pratt welcomes your email correspondence. Our associates are available
during normal business hours to address your general investment questions as
well as respond to your suggestions for improvement. At this time, however, in
order to ensure your protection and client confidentiality, our email responses
will not include any personal account information such as Social Security
numbers, account numbers, etc.
Changes to this Statement
We reserve the right to change or remove this Policy at our discretion. If we
decide to change it, we will post those changes here. We encourage you to visit
this area frequently to stay informed. If you access our web site after we have
posted changes to this Statement, you are agreeing to accept the changes.