(Protection of the Privacy of Personal Non-Public Information) Respecting and protecting customer privacy is vital to our business. By explaining our Privacy Policy to you, we trust that you will better understand how we keep our customer information private and secure while using it to serve you better. Keeping customer information secure is a top priority, and we are disclosing our policies to help you understand how we handle the personal information about you that we collect and disclose. This notice explains how you can limit our disclosing of personal information about you. The provisions of this notice will apply to former customers as well as current customers unless we state otherwise.   The Privacy Policy explains the following:

• Protecting the confidentiality of our customer information.
• Who is covered by the Privacy Policy.
• How we gather information.
• The types of information we share, why, and with whom.

  Protecting the Confidentiality of Customer Information: We take our responsibility to protect the privacy and confidentiality of customer information very seriously. We maintain physical, electronic, and procedural safeguards that comply with federal standards to store and secure information about you from unauthorized access, alteration, and destruction. Our control policies, for example, authorize access to customer information only by individuals who need access to do their work. From time to time, we enter into agreements with other companies to provide services to us or make products and services available to you. Under these agreements, the companies may receive information about you but they must safeguard this information, and they may not use it for any other purposes.   Who is Covered by the Privacy Policy: We provide our Privacy Policy to customers when they conduct business with our company. If we change our privacy policies to permit us to share additional information we have about you, as described below, or to permit disclosures to additional types of parties, you will be notified in advance. This Privacy Policy applies to both current customers and former customers.   How We Gather Information: As part of providing you with financial products or services, we may obtain information about you from the following sources:

• Applications, forms, and other information that you provide to us, whether in writing, in person, by telephone, electronically, or by any other means. This information may include your name, address, employment information, income, and credit references;
• Your transaction with us, our affiliates, or others. This information may include your account balances, payment history, and account usage;
• Consumer reporting agencies. This information may include account information and information about your credit worthiness;
• Public sources. This information may include real estate records, employment records, telephone numbers, etc.

  Information We Share: We may disclose information we have about you as permitted by law. We are required to or we may provide information about you to third-parties without your consent, as permitted by law, such as:

• To comply with requests from regulatory authorities and law enforcement officials.
• To protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability.
• To report account activity to credit bureaus.
• To respond to a subpoena or court order, judicial process or regulatory authorities.
• In connection with a proposed or actual sale, merger, or transfer of all or a portion of a business or an operating unit, etc.

In addition, we may provide information about you to our service providers to help us process your applications or service your accounts. Our service providers may include billing service providers, mail and telephone service companies, lenders, investors, title and escrow companies, appraisal companies, etc. We may also provide information about you to our service providers to help us perform marketing services. This information provided to these service providers may include the categories of information described above under “How We Gather Information” limited to only that which we deem appropriate for these service providers to carry out their functions. We use the Google Adwords search and display networks to reach customers. The Adwords platform allows us to communicate with customers using tools such as standard and custom affinity audiences, in-market audiences, and demographic and location targeting. It also allows us to monitor the performance of our ads through conversion tracking. None of the information utilized or collected in these practices is “Personally identifiable information.” We also use Google’s AdWords remarketing feature to reach specific audiences. Google utilizes cookies to display customized ads to customers who have previously visited this website (www.coveyfin.com). If you prefer not to receive these ads, you may opt out at any time by visiting Google’s Ad Settings.

We do not provide non-public information about you to any company whose products and services are being marketed unless you authorize us to do so. These companies are not allowed to use this information for purposes beyond your specific authorization.

  Website Security Policy

• The Covey Financial website has been established by Covey Financial, LLC and affiliated companies.
• Two types of access have been established for the Covey Financial, LLC website:
  • Public access sites contain information which is freely accessible, and may be viewed by any visitor. However, Covey Financial, LLC maintains a copyright interest in the contents of all of its websites. Information posted on public access sites may not be distributed or copied without obtaining permission from Covey Financial, LLC. Electronic information which is stored, transmitted, or processed on company computers or communication devices is the property of Covey Financial, LLC or its affiliates (please see the Copyright Notice).
  • Customer information sites provide restricted access to sensitive and proprietary business information. Gaining access to some types of Web-enabled information will require customers to register to view, retrieve, or process data provided by Covey Financial, LLC. Parties so authorized may not divulge or transmit this information to other external parties without permission from Covey Financial, LLC. Failure to comply with this security policy is punishable through loss of access and possible legal action for damages.
• User registration for secured access to a Covey Financial, LLC website may be required when:
  • A Web application or internal link requires user identification before processing.
  • Accessed data has been classified as “business-sensitive” and requires further authorization.
• To facilitate site management, information may be collected for statistical purposes. Company computer systems can employ software programs to compile summary usage statistics, which may be used for assessing what information is relevant to users. The data so accumulated may be used to help determine technical design specifications, identify system performance, or pinpoint problem areas.
• Except for authorized security investigations and data collection, no attempts will be made to identify individual users or their usage habits. Accumulated data logs will be scheduled for regular deletion in accordance with schedules set by Covey Financial, LLC Web administrators. The Covey Financial, LLC Website Privacy Policy details Covey Financial, LLC’s position regarding the use of personal information provided by customers/visitors.
• Unauthorized attempts to upload information or change information via any Covey Financial, LLC Web service are strictly prohibited, and may be punishable under the Computer Fraud and Abuse Act of 1986 and the National Information Infrastructure Protection Act.
• User ID and password policy:
  • Access to sensitive or proprietary business information on Covey Financial, LLC websites is limited to customers, clients and vendors who have been determined to have an appropriate business reason for having access to such data. All registered Web customers who are granted security access will be identified by a user name (referred to as the User ID). All actions performed with a User ID will be the responsibility of the ID’s registered owner.
  • Individuals who are granted password access to restricted information on Covey Financial, LLC websites are prohibited from sharing those passwords with or divulging those passwords to any third parties. User will notify us immediately in the event a User ID or password is lost or stolen or if User believes that a non-authorized individual has discovered the User ID or password.
  • By accepting password access to restricted Covey Financial, LLC websites, the User agrees to protect the identity of the password from discovery by any unauthorized third parties. To protect against anyone acquiring your password, Covey Financial, LLC suggests the following security measures:
    • Never give out your User ID or password.
    • Your password should be changed immediately if someone else identifies it. Covey Financial, LLC policy prohibits the sharing of User IDs or passwords.

 

If you have any questions or comments regarding the Covey Financial, LLC Website Security Policy, please contact Covey Financial, LLC at (210) 610-6250