PRIVACY NOTICE

 We at The Holben Group, LLC want you to know that we pride ourselves in our efforts to maintain the privacy, safeguarding and confidentiality of any personal financial information that you provide to us and that we obtain in connection with providing our financial products and services to you. We believe it is essential that we safeguard your personal financial information and have adopted the policies and procedures outlined below in order to satisfy you that we have taken steps to protect your personal financial information and to prevent it from being disclosed to parties that are not part of our network for providing you with our financial products and services.

Information We Collect
In providing our products and services to you, we collect nonpublic personal information about you from these sources:

  1. 1. Information we receive from you on applications or other forms; and

  2. Information about your transactions with us, our affiliates, or others.

  3. Information we receive from consumer reporting agencies.

  4. Other sources with your consent (for example: from your insurance professional, attorney or accountant).

Information We Disclose
We do not disclose any nonpublic personal information about you to anyone, except to provide you with our financial products and services and to carry out your instructions, and except as permitted by law consistent with these policies.

What is “Nonpublic Personal Information?”
When we refer to "nonpublic personal information," we are referring to personally identifiable financial information that we collect about you in the process of providing you with our products and services, which information has not been lawfully made available to the general public. On the other hand, publicly available information (such as governmental real estate records, published telephone numbers, etc.) is information that is lawfully available to the general public. However, "nonpublic personal information" also includes any lists or other grouping of consumer information that are created using any publicly available information from one or more clients.

Safeguards For Protecting Your Privacy
We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

Any Questions?
If you have any questions about our privacy policies, our procedures for protecting your personal financial information or any other questions or comments, please do not hesitate to contact:

Jeffrey M. Holben
Managing Partner
The Holben Group, LLC
2000 S. Colorado Blvd., Tower 2, Suite 200
303.691.1970