Privacy Policy

March, 2001

Background: On November 12, 1999, President Clinton signed the Gramm-Leach-Bliley Act into law. Subtitle A of Title V of the act, captioned “Disclosure of Nonpublic Personal Information” (“Title V”) limits the instances in which a financial institution may disclose nonpublic personal information about a consumer to nonaffiliated third parties, and requires a financial institution to disclose to all of its customers the institution’s privacy policies and practices with respect to information sharing with both affiliates and nonaffiliated third parties. Text of the entire document can be read at the http://www.sec.gov/ web site (Regulation S-P, 59 pages).

InTrack Investment Management, Inc . acknowledges our obligation to respect the privacy of our clients, and to the security and confidentiality of client nonpublic personal information. This concern impacts our prospective clients.

We use your personal information to fill out information to open your brokerage account, to offer, develop, deliver products, services and make transactions in your account(s) to benefit you. To respond to legal, regulatory requirements, to you or your legal representative, we will use your nonpublic personal information.

Nonpublic personal information will be collected from the following sources:

  • From your interactions with our firm. (Discussions with our employees, your entry of information in correspondence, or interactive tools via our web site, e-mail)
  • Verification services for credit worthiness for certain products or services you may wish to have or apply for
  • From you or your representatives regarding product, or service you may wish to have, ie. electronic confirmations vs. paper confirmations, sending statements to a third party
  • From other sources with your consent or with consent of your representative (you might transfer into existing accounts information given to other institutions and then transfer assets and positions into brokerage accounts where we do not have custody of the assets and are simply your investment advisor with trading authorization granted by you)
  • Your transaction and account balances, realized and unrealized gains and looses, interest, and dividend credited to your accounts might be sent at your request to a third party

 

We understand that the protection of your private nonpublic information is a basic trust function that we respect. We use procedural controls, electronics, and physical controls to protect your information.

We restrict access to your nonpublic information except in those instances where such information will be necessary for us to give so that you can be provided with the services you seek. (you may wish to purchase a bond from a brokerage firm that we do not conduct business with, you might want your account balance sent to a bank to qualify for a loan)

It may be necessary to provide nonpublic personal information to the following:

  • Government or law enforcement agencies (tax reporting under a court order)
  • Unaffiliated service providers which may be securities clearing houses
  • Other organizations at your or your legal representatives request (you might be applying for credit, or are in need of a financial reference
  • Other organizations may need your information to prevent fraud

 

PRIVACY ONLINE

  • Brokerage firms that provide you with access to their online services have extensive firewalls, encryption techniques and procedures in place to make sure that your nonpublic personal information is confidential.
  • We do not collect technical or navigational information as a firm. Brokerage firms may do this to improve the design of their web site or to alert you of a news item on a certain security that you may hold in your account with them.
  • Our internal systems are password protected for security.
  • It is important that you safeguard your own personal information by taking a few simple precautions. Protect your account, PIN, and customer access numbers. Never disclose confidential information to unknown callers. When using the internet be sure to use a secure browser and current virus detection software, and never open e-mail from unknown sources..

 

YOUR CONNECTION WITH INTRACK INVESTMENT MANAGEMENT, INC.

  • We collect information from you that is shared with particular brokerage firms on your behalf. This information is not shared with third parties other than those that need specific information to meet your or your representatives need to disclose information to execute a transaction.
  • You may contact us by e-mail msopher@intrackinvest.com: , by phone, through our web site: www.intrackinvest.com , by mail, or FAX.
  • Information you provide to us is only to be used for the stated purpose.
  • Any misuse of this information by an employee will be considered a violation of this policy, and that employee will face disciplinary action.
  • Management will make reasonable efforts to review this policy on an ongoing basis to ensure that it is followed. All staff members will be asked to review and discuss this policy and our goals related to it.
  • Any violation to this policy should be reported to management immediately.
  • E-mail which you send to us is kept on file, printed or stored depending upon SEC requirements. You may also require us to keep information.
  • We will not share your e-mail addresses with anyone outside of our firm unless you provide us with permission to do so.