At Creative Benefit Strategies, Inc., we value the trust you have placed in us and we intend to continue to earn your trust each day. That's why we welcome this opportunity to describe our privacy policies and the steps we take to protect your customer information. In this brochure, you'll find details about these policies and procedures, as well as the opportunity to choose how your customer information may be shared. You'll also receive updates in the future, so you can continue to stay informed about this important issue.
This disclosure applies to consumers who have a relationship with Creative Benefit Strategies, Inc.
The practices and policies contained in this disclosure are subject to change, but we will communicate any material changes to you when required by applicable laws. The practices and policies contained in this disclosure replace all previous notices or statements with respect to the same subject matter.
We are committed to protecting your privacy at all times.
We do not share customer information with outside companies for purposes of marketing non-financial products and services to you, unless you have been given the opportunity in advance to decline this option.
We are committed to bringing you the services you need to succeed financially. If we do not offer a financial service, such as some insurance products, we may establish a joint marketing program with an outside company to offer that service to you. These programs include confidentiality agreements to protect customer information.
We maintain security standards and procedures designed to protect customer information. We will continue to test and update our technology to improve the protection of our information about you.
We want you to know that you can count on us to protect the privacy and security of your customer information, and to provide you with the responsive, professional service you deserve.
Our Policies Regarding The Collection, Use and Disclosure of Customer Information
We are committed to providing you with responsive, personalized service, and keeping you informed about new services that may be of immediate interest to you, or new benefits that can help you derive the greatest value from your relationship with us. Customer information is at the heart of our ability to provide superior service to you. In the sections that follow, we describe the types of information that are collected, and how and why that information may be shared with others.
The primary reason that we collect and maintain customer information is to serve you and administer your customer relationship. This information may be collected from a variety of sources, such as the following: Information you provide to us on applications or forms, like your income and accounts; Information we receive from an outside company, such as an insurance company, investment fund company or advisory firm;
Information about your transactions or experiences with companies within the Creative Benefit Strategies, Inc. family.
Information Use and Disclosure...
...Within the Creative Benefit Strategies, Inc. Family
We use and share customer information within the Creative Benefit Strategies, Inc. for a variety of reasons, including the following:
To protect you. The information we maintain about your customer relationship helps us identify your investment goals and monitor the suitability of securities products and investment advice provided. To secure your accounts and protect you from fraud.
To provide superior service. Your customer information allows us to respond quickly and efficiently to your needs.
To tell you about new or enhanced financial services. By understanding your relationship, we can better meet your needs and determine your eligibility for other Creative Benefit Strategies, Inc. services that could be of value to you.
To improve and develop our products and services that may more closely meet your objectives, thereby benefiting you.
Within the Creative Benefit Strategies, Inc. family, we may share the customer information we collect (described in the Information Collection section)
....With Outside Companies or Parties
When it comes to sharing information outside the Creative Benefit Strategies, Inc. family, we do so only for specific purposes. We may disclose customer information to the following types of outside companies or parties:
Financial service providers such as insurance companies, trust companies, investment advisors where and when you have specifically applied for a service or product provided, or to be provided, by that affiliated financial service provider.
We do not share customer information with outside companies for the purpose of marketing non-financial products or services of those companies, unless you have been given the opportunity in advance to decline this option (that is, to "opt out" of this type of sharing).
Some state laws impose separate requirements before we can disclose particular types of information about customers in those states to outside parties for certain marketing programs or other purposes.
Information Disclosed to Outside Financial Service Providers
We do not share information with outside companies for the purpose of selling their products and services to you without giving you the opportunity in advance to decline this option (that is, to "opt out" of this type of sharing). As permitted by law, we arrange programs with outside financial service providers to offer you the benefits of "one-stop shopping" or other conveniences. In these cases, unless you exercise your choice to opt out of this type of sharing, we sometimes disclose the following categories of limited customer information with outside financial institutions with which we have joint marketing agreements:
Information we receive from you on applications or forms, which may include information such as your name, address, and social security number;
Information about your transactions or experiences with companies within the Creative Benefit Strategies, Inc. family.
We disclose information only when we believe that this information is important for the offer, or necessary to provide you with a premium or rate quote. Our joint agreements with these companies are subject to confidentiality provisions and restrictions on using the information for any other purpose.
Information Disclosed to Outside Non-financial Companies and Independent Contractors
When outside parties perform services on our behalf in some instances we may disclose some or all of the information that we collect, as described in the Information Collection section. This information may be provided to certain non-financial companies and independent contractors for the purposes of servicing your account or to perform marketing or similar services on our behalf with respect to products or services we provide. These companies and contractors are subject to confidentiality provisions and restrictions that prohibit using the information beyond the performance of the specified services on our behalf.
Information Disclosed to Outside Parties in Other Situations
We also disclose certain customer information to government agencies, consumer reporting agencies, and other outside parties as permitted or required by the Federal Privacy Act and other applicable laws. These disclosures are made for specific, limited purposes, such as to verify individuals' identities (reducing fraud and identity theft), to meet customer service expectations, to verify information for prompt approvals (meeting customers' immediate financial needs), responding to a subpoena, or to make certain information a matter of public record.
Our Policies Regarding the Collection, Use and Disclosure of Information about Former Customers
Our policies and practices regarding the collection and disclosure of information about former customers are the same as those regarding the collection and disclosure about existing customers (see the section titled Our Policies Regarding the Collection, Use and Disclosure of Customer Information) for a period of time after a customer relationship ends. Our information about former customers, however, is used less and less over time after the relationship ends and eventually is removed from our records.
Information Confidentiality Protection Practices
Creative Benefit Strategies, Inc. is committed to preventing others from Unauthorized access to your customer information, and we maintain procedures and technology designed for this purpose. We take several steps to protect the customer information we have about you, including the following:
We require outside companies and independent contractors to whom we provide customer information for marketing, servicing or processing purposes to enter into a confidentiality agreement that restricts the use of the information to those purposes and prohibits independent use of the information.
We have internal procedures that limit access to customer information, such as procedures that require an employee to have a business need to access customer information.
We maintain policies about the proper physical security of workplaces and records. Our physical, electronic, and procedural safeguards comply with federal regulations regarding the protection of customer information.
Information Integrity Measures
We work hard to ensure that the customer information we maintain is complete and accurate. We have procedures and processes for updating our customer information as well as removing old information. We protect the integrity of customer information about you through measures such as maintaining backup copies of account data in the event of power outages or other business interruptions, using computer virus detection and eradication software on systems containing customer data, installing computer hardware and software, and employing other technical means (known as "firewalls") to protect against unauthorized computer entry into systems containing customer information.
Customer Choices Regarding Information Sharing
We are committed to protecting customer information, and to using or sharing it in ways that will improve or expand upon the services we provide to you. We also want you to know that, as a Creative Benefit Strategies, Inc. customer, you have choices about how your customer information may be shared. Please be assured that you may exercise these choices at any time. In addition, if you have opted out of information sharing previously, it is not necessary to do so again.
With Outside Companies (Option 1)
We may share limited customer information under special agreements with outside financial service providers in order to offer you financial products that we typically do not offer ourselves. Some of this information helps to ensure that you will receive those communications that are most likely to match your needs or situation.
If you prefer that we not share this information about you with these outside financial service providers for these purposes, you may choose to opt out. This means that you may direct us at any time not to disclose this information to these outside providers for marketing purposes. If you wish to opt out of this type of sharing, simply notify us as described and your request will be honored.
Within the Creative Benefit Strategies, Inc. Family (Option 2)
The staff within the Creative Benefit Strategies, Inc. family share some information about you among themselves to determine your eligibility for products and services to be offered to you. This helps us meet your financial needs and offer the right products and services to you.
If you prefer that we don't share your customer information with other companies associated with Creative Benefit Strategies, Inc. for these purposes, you may choose to opt out. You may direct us not to disclose this information to financial institutions to determine your eligibility for their products and services. If you wish to opt out of this type of sharing, simply notify us as described in this brochure at any time and your request will be honored by all companies associated with Creative Benefit Strategies, Inc.
In accordance with the Fair Credit Reporting Act, whether or not you have opted out, we may share identifying information and information about your transactions and experiences within the Creative Benefit Strategies, Inc. family.
Additional Information About These Choices
We are committed to meeting your financial needs. >We want you to know that, regardless of any opt out choice you make, there may be occasions when we will ask you if you wish your information to be shared. For example, if we are unable to offer you a particular Creative Benefit Strategies, Inc. product that you applied for, we may offer you the opportunity to have us forward your application and related information to another Creative Benefit Strategies, Inc. affiliated financial institution for a similar product.
How To Notify Us
If you decide to opt out, please indicate your choice(s) as described and include your name, address, and Social Security Number or Tax Identification Number. Mail the request to us at the following address:
Creative Benefit Strategies, Inc.
P.O. Box 810
Clarkston, MI 48347
You may also call us at 1-800-486-8680 or 248-328-8611.
If you have a joint account, each account holder may select either or both option. Any account holder can opt out on behalf of the other joint account holders.
If you have previously communicated an opt out choice to us, you do not have to provide it again.
Option 1: Please do not share information with outside companies for marketing purposes as described in this brochure. I understand that I will not receive information, available through special agreement between the outside company and Creative Benefit Strategies, Inc., about financial services or products that are not available through Creative Benefit Strategies, Inc.
Option 2: Please do not share information within the Creative Benefit Strategies, Inc. family, as described in this brochure. I understand that I won't receive information about new services or special offers for which I may be eligible.