Tolis collects nonpublic personal information about its clients from the following sources:
- Information Tolis receives from a client in subscription documents or other related documents or forms;
- Information about a client’s transactions with Tolis, its affiliates, or others; and
- Information Tolis may receive from a consumer reporting agency.
Tolis does not disclose any nonpublic personal information about its prospective, existing or former clients to anyone, except as permitted by law and regulation.
Tolis restricts access to nonpublic personal information about its clients to those employees and agents of Tolis who need to know that information in order to provide services to its clients. Tolis may also disclose such information to its affiliates and to service providers and financial institutions that provide services to Tolis. Tolis will require such third party service providers and financial institutions to protect the confidentiality of the clients’ nonpublic personal information and to use the information only for purposes for which it is disclosed to them. Tolis maintains physical, electronic, and procedural safeguards that comply with U.S. federal standards to safeguard clients’ nonpublic personal information and which Tolis believes are adequate to prevent unauthorized disclosure of such information.