PRIVACY NOTICE
Commune Capital, LLC. (hereinafter “Commune”) strongly believes in protecting the confidentiality and security of information we collect about individuals. This notice describes the privacy policy followed by Commune:
- How we treat the information we receive (“Information”) about individuals who apply for or obtain our products or services (“Individuals”); and
- Any third parties with whom we may share this Information with.
INFORMATION WE COLLECT
“Nonpublic Personal Information” is nonpublic information about the Individual that we obtain in connection with providing a financial product or service to the Individual for personal, family, or household purposes.
We collect Nonpublic Personal Information about Individuals from the following sources:
INFORMATION DISCLOSED TO THIRD PARTIES, SERVICE PROVIDERS AND JOINTMARKETING PARTNERS
We do not disclose any Nonpublic Personal Information about our customers or former customers to third parties, except upon permission from such Individual or upon direction of a court of law or other government authority, or to our service providers as outlined below.
Nonpublic Personal Information may be disclosed as necessary to service provider institutions. Such institutions presently include financial service institutions such as custodians and broker-dealers through whom customers’ transactions are executed, and technology service providers such as our database programmers. All service providers must limit their use of information to the purpose for which it was provided.
We do not currently have joint marketing partners to whom we disclose any Nonpublic Personal Information. In the event that we decide to engage in such a relationship, we will obtain permission from customers or former customers to disclose any Nonpublic Personal
Information. Furthermore, these institutions will be prohibited by agreement from using such Nonpublic Personal Information except for the narrow purpose for which it was given to them.
PROTECTING CONFIDENTIALITY AND SECURITY
We treat Information in a confidential manner. Our employees are required to protect the confidentiality of Information. Employees may access Information only when there is an appropriate reason to do so, such as to administer or offer our products and services.
Employees are subject to disciplinary rules if they do not comply with our policies. We also maintain physical, electronic, and procedural safeguards to protect Information; these safeguards comply with all applicable laws.
DISCLOSURE OF INFORMATION ABOUT FORMER CUSTOMERS
If an Individual decides to close an account or otherwise becomes an inactive customer, we will continue to follow the privacy practices described in this notice with respect to such Individual.