PRIVACY POLICY
Pembroke Asset Advisors Privacy Policy
Pembroke collects nonpublic personal information about you from the following sources:
Ø Information we receive from you on applications or other forms;
Ø Information about your transactions with us or others; and
Ø Information we receive from a consumer reporting agency.
The Firm does not sell, rent or otherwise provide your data to unaffiliated third parties for marketing purposes. We use third party software and share data only as needed to perform the services we have agreed to perform for you. If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.
Pembroke restricts access to your personal and account information to those employees who need to know that information to provide products or services to you. Pembroke maintains physical, electronic, and procedural safeguards to guard your nonpublic personal information.
The following employees will manage nonpublic information: Robert Michael Menzies
The following individuals also have access to this nonpublic information: Robert Michael Menzies, Arika S Menzies, contracted employees of Compliance Risk Concepts, LLC.
The following systems may be vulnerable to a breach of your nonpublic information: Microsoft Office suite of products.
To mitigate a possible breach of the private information Pembroke will encrypt all data that individuals have access to or use password sensitive documents. The system will be tested and monitored regularly.
Pembroke has taken extensive measures to safeguard the privacy and integrity of the information that it gathers, stores, and archives during its normal business practices. Computer security measures have been instituted where applicable including passwords, backups, and encryption. All employees are informed and instructed on various security measures including the non-discussion and/or sharing of client information, always removing client files from desktops or working areas that cannot be locked or secured, and proper storage of client securities files in locked files or other secured location. Pembroke uses various methods to store and archive client files and other information. All third-party services or contractors used have been made aware of the importance Pembroke places on both firm and client information security. In addition to electronic and personnel measures Pembroke has implemented reasonable physical security measures at our home office location, and encouraged all remote locations, if any, to do the same to prevent unauthorized access to our facilities.
Pembroke will retain records for at least 5 years, or as otherwise required by applicable state or federal law. With respect to disposal of nonpublic personal information, Pembroke will take reasonable measures to protect against unauthorized access to or use of such information in connection with its disposal.
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Rev. 06/10/2022