Privacy Policy
Revised: December 2018
What Information We Collect
The Kings Counsel & Trust (KCT) Family Office (KCTFO) and its KCT Members are committed to protecting the confidentiality and security of information we collect about our existing and prospective KCT Members. We will not share non-public information about you (the "Information") with third parties outside of KCTFO without your consent, except for the specific purposes described below. This notice describes the Information we may gather and the circumstances under which we may share it.
We collect nonpublic personal Information about you from the following sources:
- Information we receive from you on applications, tax organizers, worksheets, and other documents
- Information about your transactions and exchanges with us, our affiliates, or others
- Information we receive from a consumer-reporting agency.
We restrict access to nonpublic personal Information about you to those KCTFO Members who need to know that Information to offer counsel and provide services to you. We maintain physical, electronic, and procedural safeguards that meet or exceed federal regulations to guard your nonpublic personal information.
Why We Collect and How We Use Information
We limit the collection and use of Information to the minimum we require to deliver superior service to you and for your protection. Such services include processing various requests by you, assessing qualifications and capabilities, inventory, and due diligence analysis, providing advice to you, and administering our services.
How We Gather Information
We get most Information directly from you when you apply for, access, and/or use products, services, and/or research offered through KCTFO – whether in person, by telephone, or electronically. We may verify this Information or get additional Information from consumer reporting agencies or public sources. This Information may relate to your finances, employment, vocations, or other personal characteristics, as well as transactions and interactions with KCTFO Members, or others.
How We Protect Information
The KCTFO and its KCT Members are required to protect the confidentiality of Information and to comply with our established policies. They may access Information only when there is an appropriate reason to do so, such as to administer various services and/or distribute resources. We also maintain physical, electronic, and procedural safeguards to protect Information. Those that violate this KCTFO Privacy Policy are subject to disciplinary process and/or termination according to our KCTFO Conflict Resolution Policy.
Disclosure of Information
We do not disclose any non-public Information about our KCTFO Members or former KCTFO Members to anyone unaffiliated with KCTFO and/or without cause. We may disclose any Information to or as directed by a KCTFO Member or when we believe it necessary for the conduct of our KCTFO affairs, or where disclosure is required or permitted by law. Information may be disclosed for audit or research purposes, to attorneys or other professionals, or to law enforcement and regulatory agencies, for example, to help us prevent fraud. In addition, we may disclose Information to affiliated and non-affiliated third-party service providers (i) to enable them to provide business services for us, such as performing computer-related or data maintenance or processing services, (ii) to facilitate the processing of transactions requested by you, (iii), to assist us in offering products and services to you or to assist our KCTFO Members in offering products and services to you, or (iv) for credit review and reporting purposes. Except in those specific, limited situations, without your consent, we will not disclose Information to any unaffiliated organization that may want to sell their products or services to you. For example, we do not sell client lists, and we will not sell your name to a catalogue company. It is KCTFO policy to require all third parties, including our KCTFO Members, that are to receive any Information to acknowledge this KCTFO Privacy Policy and related written policies and supervisory procedures.
Important Note: KCTFO has one foundational covenantal agreement and a series of voluntary supplements for all prospective KCTFO Members without partiality (e.g., house rules): they are non-negotiable and available for review upon receiving KCTFO Member status. Please reference KCTFO Policy - Why we say ‘No’ to Legalism … and you should too, as we do not ordinarily acknowledge third-party confidentiality agreements and similar documents.
Former Relationships
Even if you are no longer affiliated with us, this KCTFO Privacy Policy will continue to apply to you according to the covenants of your former relationship with KCTFO.
To Whom This Policy Applies
This KCTFO Privacy Policy applies to products or services provided by KCTFO Members through and across the various KCTFO platforms.
Access to and Correction of Information
If you desire to review any file we may maintain of your personal Information, please contact us. If you notify us of any incorrect Information, we will review it. If we agree, we will correct our records. If we disagree, you may submit a short statement of dispute, which we will include in future disclosures of the disputed Information. Information collected in connection with, or in anticipation of, any conflict resolution proceeding will not be made available.
Further Information
We reserve the right to change this KCTFO Privacy Policy. The examples contained within this KCTFO Privacy Policy are illustrations, and they are not intended to be comprehensive or exclusive. This privacy notice does NOT comply with enacted federal law and related governmental regulations regarding privacy (i.e., KCTFO will not disclose your personal information to any government or agency thereof, just because they asked for it) as this would cause KCTFO to breach its own covenants with you. You may have additional rights under other foreign or domestic laws that may apply to you.
Related KCTFO References