The relationship between Evermay Wealth Management, LLC (referred to as “Evermay Wealth Management,” our,” “us,” or “we”) and our clients is the most important asset of our firm. We strive to maintain your trust and confidence in our firm, an essential aspect of which is our commitment to responsible management, use and protection of your personal information to the best of our ability. We believe that all of our clients value their privacy, so we will not disclose your personal information to anyone unless the law requires it, you have directed us to do so, or it is necessary to provide you with our services.
We pledge to maintain the confidentiality of your personal information in our possession, in accordance with the disclosures in this privacy notice.
SOURCES AND CATEGORIES OF PERSONAL INFORMATION WE COLLECT
When you establish a relationship with us, you are requested to furnish personal and financial information to assist in assessing your financial objectives and goals. The information you share with us is private and confidential, and we are committed to protecting your privacy. In addition to the information collected, during the course of our relationship we may also collect a variety of personal information, including nonpublic personal information, from other sources.
We collect personal information about you from the following sources in connection with providing our services:
- personal information we receive from you (such as name, address, date of birth, social security number, and all personal and financial information we learn in performing investment management and wealth planning reviews on your behalf), whether personally or in writing, by telephone or otherwise;
- personal information about your transactions with us or others (such as trade tickets, trade confirmations and account statements;
- personal information we receive, with your authorization, from third parties such as accountants, legal counsel, financial advisors, insurance agents, banking institutions, brokerage firms and others.
WHAT PERSONAL INFORMATION DO WE COLLECT WHEN YOU VISIT OUR SITE?
When you visit our Site, we collect information from you when you register or fill out a form. We are the sole owners of the information collected on this Site. We will not sell or share this information with anyone unless otherwise specified.
HOW IS YOUR PERSONAL INFORMATION USED?
We will only use your personal information with the purpose to provide you with our investment services. In managing your investment for you, we will use your personal information to:
- monitor, audit, evaluate and otherwise administer our services;
- provide you with access to protected areas of our Site;
- provide continuous service to you and to conduct business processing functions including by providing personal information to our contractors, service providers, or other third parties;
- assist with the administrative, marketing (including direct marketing), planning, or service development, quality control or research purposes of Evermay Wealth Management and its contractors and service providers;
- communicate with you and respond to your inquiries;
- protect against, identify and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other unlawful activity, claims and liabilities;
- perform data analyses (such as market and customer research);
- pursue our legitimate interests;
- conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms; and/or
- for other purposes required or authorized by law, including other purposes for which you have provided your consent.
In the event that we use personal information we collect for other purposes not identified above where direct client consent is required under applicable rules, laws and/or regulations we will provide specific notice at the time we collect such personal information.
LAWFUL BASIS FOR PROCESSING
Evermay Wealth Management may have one or more of the following lawful bases to process your personal information:
- Consent: your freely, informed, and voluntary consent to process your personal information in connection to our investment services.
- Contract: processing your personal information is necessary in order to fulfill a contract.
- Legal Obligation: processing is necessary to comply with applicable rules, laws, and regulations.
- Legitimate Interests: processing is necessary to the legitimate interests of our firm and/or a third party.
DISCLOSURE OF YOUR PERSONAL INFORMATION TO THIRD PARTIES
Disclosure of any personal information about our former clients is handled in the same manner as for our current clients.
- Evermay Wealth Management does not sell its current or former customers’ non-public personal information to any third parties and does not disclose any non-public personal information about our current or former customers without their authorization, except that we may disclose information as follows:
- Evermay Wealth Management may disclose information to non-affiliated third-parties in connection with our performance of the services we have agreed to provide you, such as to process transactions or to otherwise maintain your account;
- Evermay Wealth Management may disclose information if specifically required to do so by judicial or regulatory processes or as permitted by law; and
- Evermay Wealth Management may disclose any information that we have collected about you to non-affiliated third-parties that perform services for us on our behalf, such as our professional advisors (e.g., consultants, accountants, and attorneys), and vendors we hire to provide support for our services. These third-parties, however, act on our behalf and
- The disclosure of information contained in any document completed by the client for processing and/or transmittal by Evermay Wealth Management to facilitate the commencement/continuation/termination of a business relationship between the client and/or between Evermay Wealth Management and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, record keeper, insurance company, etc.), including, but not limited to, information contained in any document completed and/or executed by Evermay Wealth Management the client in furtherance of the client's engagement of Evermay Wealth Management (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider.
In the section below pursuant to U.S. Federal Laws, we list the reasons financial companies can share their customers’ personal information; the reasons Evermay Wealth Management Investment Management, LLC chooses to share; and whether you can limit this sharing.
|Reasons we can share your Personal Information||Does Evermay Wealth Management Investment Management, LLC share?||Can you limit sharing?|
|For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus||Yes||No|
|For our marketing purposes — to offer our services to you||Yes||Yes|
|For joint marketing with other financial companies||No||We don’t share|
|For our affiliates’ everyday business purposes — information about your transactions and experiences||N/A||N/A|
|For our affiliates’ everyday business purposes — information about your creditworthiness||N/A||N/A|
|For our affiliates to market to you||N/A||N/A|
|For nonaffiliates to market to you||No||We don’t share|
LIMITS ON SHARING
To the extent U.S. Federal laws apply to your personal information, you have the right to limit only:
- sharing for affiliates’ everyday business purposes—information about your creditworthiness;
- affiliates from using your information to market to you; and
- sharing for nonaffiliates to market to you.
U.S. state laws and individual companies may give you additional rights to limit sharing.
To the extent permitted by the applicable law of your jurisdiction, in relation to your personal information, you may request:
- to have your personal information corrected, for example, if it is incomplete or incorrect;
- to opt out of receiving marketing communications at any time;
- the right to file a complaint with an applicable government regulator such as a Data Protection Authority.
In addition to the foregoing, if you are located in the European Economic Area (“EEA"), to the extent permitted by applicable law, in relation to your personal information, you may request:
- to access the personal information held by us about you;
- the right to restrict or object to the processing of your personal information, or request that your personal information is erased;
- the right to receive a copy of the personal information which you have provided to our firm, in a structured, commonly used and machine-readable format (known as “data portability”);
- have a copy of the personal information we hold about you provided to you or another controller where technically feasible;
- where you have provided personal information voluntarily, or otherwise consented to its use, the right to withdraw your consent.
To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to your information.
To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.
WILL YOUR PERSONAL INFORMATION BE KEPT ACCURATE, COMPLETE AND UP TO DATE?
We will endeavor to ensure your personal information is kept accurate, complete, up to date and relevant. Please let us know if any of your details change. If you feel your personal information is not accurate, complete or up to date, please notify us and we will take reasonable steps to ensure it is corrected. You can contact us using the details listed below.
IS YOUR PERSONAL INFORMATION SECURE?
Evermay Wealth Management continually updates and improves security standards and procedures to guard against anyone gaining unauthorized access to your Information, including through the Internet. We maintain physical, electronic and procedural safeguards to guard your personal information.
Evermay Wealth Management maintains appropriate physical, electronic, and procedural safeguards that comply with applicable legal standards to protect its clients' personal information. Through this policy and its underlying procedures, Evermay Wealth Management attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.
As our Site is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
Links to Third-Party Web Sites
As a convenience to you, Evermay Wealth Management may provide hyperlinks to web sites operated by third parties. When you select these hyperlinks, you will be leaving our Site.
Evermay Wealth Management has no control over third party web sites, their content, or security. Accordingly, when you access these third party web sites it is at your own risk. We encourage you to read the associated privacy policies by such third party web sites to learn more about their data privacy management practices. Evermay Wealth Management may, in its sole discretion, block links to our Site and Content without prior notice.
RETENTION OF PERSONAL INFORMATION
To the extent permitted by applicable law, we retain your personal information for the period necessary to serve the purposes for which we obtained it. We may also retain your personal information beyond such period in accordance with applicable laws, regulations, or another lawful basis, including but not limited to, compliance with our contractual obligations, legal obligations, regulatory obligations, legal claims, or another legitimate interest.
Retention of Cookies
When you visit our Site, we retain certain “cookies” for a period of time. For more information about how our firm retains cookies, please refer to our Cookies Policy.
DO WE USE “COOKIES” OR OBTAIN PERSONAL INFORMATION BY AUTOMATED MEANS?
Cookies are small text files that are stored in your computer's memory and hard drive when you visit certain web pages. They are used to enable a website to function or to provide information to the owners of a web site.
Automated Decision Making. This Site contains cookies that function as an automated decision-making mechanism to determine user location.
Amending internet browser settings to disable cookies. You can configure your browser to send accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies that have already been set. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. You are free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on our Site. In addition, a number of companies offer utilities designed to help you visit web sites anonymously.
For more information about cookies and how to disable them please visit www.allaboutcookies.org, or you may consult the vendor documentation for your specific software.
For more information on how our firm utilizes cookies, please refer to our Cookies Policy.
HOW DO WE RESPOND TO DO NOT TRACK SIGNALS?
We do not track users across time or over multiple web sites, we do not receive, or respond to, browser do-not-track signals or other similar mechanisms. However, as noted above, some third party web sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.
Amending your internet browser’s Do Not Track signal: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers and is a way for users to inform a web site and its associated services that they do not want certain information about their webpage visits collected over time and across web sites or online services.
To learn more about setting up a Do Not Track signal, please visit https://allaboutdnt.com/.
For more information on how our firm responds to Do Not Track signals, please refer to our Cookies Policy.
INFORMATION ABOUT CHILDREN
Our Site is not directed to children under the age of 18 years. By using our Site, you represent and warrant that you are at least 18 years old. We do not knowingly solicit or collect personal information on the site from children under the age of 18 without prior verifiable parental consent.
If you are located in the European Economic Area (“EEA"), we will comply with applicable legal requirements regarding the provision of appropriate safeguards for the transfer of personal information to recipients in countries for which the European Commission has not issued an adequacy decision.
As identified under applicable law, the data controller for this Site is Evermay Wealth Management located at the address below.
We want to assure you that we are committed to maintaining the confidentiality, integrity and security of your personal information. The safeguarding of client information is an issue we take seriously; whenever information is used, it is done with discretion.
We have developed these privacy policies to protect our clients. These policies are for general guidance and do not constitute a contract or create legal rights and do not modify or amend any agreement we have with our clients.
WHOM CAN YOU CONTACT AT EVERMAY WEALTH MANAGEMENT?
Attention: Damon White, Chief Compliance Officer
Evermay Wealth Management, LLC
1776 Wilson Boulevard, Suite 310
Arlington, VA 22209
Phone: (703) 822-5696
Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies.
- Evermay Wealth Management does not have any affiliate companies
Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies.
- Evermay Wealth Management does not share with nonaffiliates so they can market to you.
Joint Marketing: A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
- Evermay Wealth Management does not jointly market.