Maintaining the trust and confidence of our clients is a high priority. That is why we want you to understand how we protect your privacy when we collect and use information about you, and the steps that we take to safeguard that information. This notice is provided to you on behalf of Presilium Private Wealth, LLC (“Presilium”).
Information We Collect: In connection with providing investment products, financial advice, or other services, we obtain non-public personal information about you, including:
• Information we receive from you on account applications, such as your address, date of birth, Social Security Number, occupation, financial goals, assets and income;
• Information about your transactions with us, our affiliates, or others;
• Information about your visits to our website. We store records of the activities on our sites in our web server logs, which automatically capture and save the information electronically. The information we collect helps us administer the site, analyze its usage, protect the website and its content from inappropriate use, and improve the user’s experience.
Categories of Information We Disclose: We may only disclose information that we collect in accordance with this policy. Presilium does not sell customer lists and will not sell your name to telemarketers.
Categories of Parties to Whom We Disclose: We will not disclose information regarding you or your account at Presilium, except under the following circumstances:
• To entities that perform services for us or function on our behalf, including financial service providers, such as a clearing broker-dealer, investment company, or insurance company, other investment advisers;
• To comply with broker-dealer firms that have regulatory requirements to supervise certain representatives’ activities;
• To third parties who perform services or marketing, client resource management, or other parties to help manage your account on our behalf;
• To your attorney, trustee or anyone else who represents you in a fiduciary capacity;
• To our attorneys, accountants, or auditors; and
• To government entities or other third parties in response to subpoenas or other legal processes as required by law or to comply with regulatory inquiries.
How We Use Information: Information may be used among companies that perform support services for us, such as data processors, client relationship management technology, technical systems consultants, and programmers, or companies that help us market products and services to you for a number of purposes, such as:
• To protect your accounts/non-public information from unauthorized access or identity theft;
• To process your requests such as securities purchases and sales;
To establish or maintain an account with an unaffiliated third party, such as a clearing broker-
dealer providing services to you and/or Presilium;
• To service your accounts, such as by issuing checks and account statements;
• To comply with Federal, State, and Self-Regulatory Organization requirements;
• To keep you informed about financial services of interest to you.
Regulation S-AM: Under Regulation S-AM, a registered investment adviser is prohibited from using eligibility
information that it receives from an affiliate to make a marketing solicitation unless: (1) the potential marketing
use of that information has been clearly, conspicuously and concisely disclosed to the consumer; (2) the
consumer has been provided a reasonable opportunity and a simple method to opt out of receiving the
marketing solicitations; and (3) the consumer has not opted out. Presilium does not receive information
regarding marketing eligibility from affiliates to make solicitations.
Regulation S-ID: Regulation S-ID requires our firm to have an Identity Theft Protection Program (ITPP) that
controls reasonably foreseeable risks to customers or to the safety and soundness of our firm from identity
theft. We have developed an ITPP to adequately identify and detect potential red-flags to prevent and mitigate
Our Security Policy: We restrict access to nonpublic personal information about you to those individuals who
need to know that information to provide products or services to you and perform their respective duties. We
maintain physical, electronic, and procedural security measures to safeguard confidential client information.
Cyber Security: Internal policies and procedures are in place to address cyber security. A copy of this policy is
available upon request.
Departing Investment Adviser Representatives (“IARs”): If your IAR’s affiliation with Presilium ends and
he or she joins a non-affiliated securities broker-dealer or registered investment adviser, Presilium will permit
the IAR to use certain client contact information to solicit clients to join the IAR’s new financial services
provider. The client contact information that the IAR may use is limited to your name, address, email address,
phone number and account title.
Certain states have adopted a requirement for you to approve the sharing of information in advance, otherwise
known as an “opt-in” choice. If you live in an “opt-in” state (e.g., California, Massachusetts, Maine, Alaska, North
Dakota or Vermont), then Presilium will require your consent to share your information with unaffiliated third
parties who are not servicing your account. State requirements vary and may change without notice.
Your Right to Opt Out: Federal privacy laws give you the right to restrict us from sharing your personal
financial information. These laws balance your right to privacy with Presilium’s need to provide information
for normal business purposes. You have the right to opt out of sharing certain information with affiliated and
unaffiliated companies of our firm. Choosing to restrict the sharing of your personal financial information will
not apply to (1) your information that we may share with companies that help promote and market our own
products or products offered under a joint agreement with another company; (2) records of your transactions-
-such as your loan payments, credit card or debit card purchases, and checking and savings account statements-
-to firms that provide data processing and mailing services for our firm; (3) information about you in response
to a court order; and (4) your payment history on loans and credit cards to credit bureaus. If you opt out, you
limit the extent to which Presilium can provide your personal financial information to non-affiliated companies.
Closed or Inactive Accounts: If you decide to close your account(s) or become an inactive customer, our
Complaint Notification: Please direct complaints to: Brook Hart at Presilium Private Wealth, LLC, 1601
Market Street, Philadelphia, PA 19103; (215) 982-4140.
contact us at: Presilium Private Wealth, LLC, 1601 Market Street, Philadelphia, PA 19103; (215) 982-4140.