Effective June 2020

Silver is committed to complying with all applicable privacy requirements in order to protect personal information of its current, former and prospective clients (each referred to herein as a “Client” and collectively as “Clients”).  Silver has established this Privacy Policy (the “Policy”) to share with you how Silver collects, uses, shares and protects its Clients’ personal information, as identified below (“Personal Information”).

Silver collects Personal Information in order to contact and communicate with Clients, for purposes of providing advice and services to its Clients and as part of certain marketing activities.  Personal Information that may be collected by Silver includes, but is not limited to, name, company name, address, phone, electronic mailing address, bank account and wiring instructions and other data provided by a Client.  Silver will retain Personal Information for a reasonable period of time, considering actual business requirements to obtain and retain such information. Personal Information will also be retained for a period of time required to comply with state, local and federal regulations.

Silver will use, disclose and otherwise process Personal Information for business, administrative and marketing purposes.  Personal Information is not shared with any unaffiliated third parties for marketing purposes.  From time to time, Silver may share Personal Information with external third parties.  Examples may include sharing Personal Information with vendors, outside counsel, accountants, consultants and other service providers who are performing certain services on behalf of Silver; in response to lawful requests by public authorities, including meeting national security or law enforcement requirements as necessary and permissible under applicable laws; and, if Silver’s business enters into a joint venture with or is merged with another business entity.

Silver strives to protect Personal Information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, replication, use or modification.  Silver maintains appropriate administrative, technical and organizational controls to safeguard Personal Information, although such safeguards may not prevent all breaches of information security.  If the security of Personal Information is compromised, the affected Clients will receive notice of the data security incident where required by, and consistent with, applicable law.

Clients may exercise their rights under applicable law to access Personal Information as is held by Silver, to rectify or delete any Personal Information which is factually incorrect, inadequate or irrelevant for the purpose for which it is processed and to raise any questions or concerns as to the use of their Personal Information, including making a request not to receive marketing materials, by reaching out to Silver.

In order to use and disclose such Personal Information for the purposes described above, although unlikely, such Personal Information may be transferred internationally to countries which the European Union has deemed not to provide adequate data protection.  Clients recognize the necessity of such international processing of Personal Information and consent to such international transfers of Personal Information, as Silver deems appropriate.  Silver will ensure application of the same standards of privacy protection as set out in this Privacy Policy regardless of the country in which such Personal Information is processed.

The Policy is effective as of the date above.  If, at any time in the future, it is necessary to disclose any Personal Information in a way that is materially inconsistent with this Policy, Silver will give the Client written notice of the change and, where required under applicable law, obtain consent to such change.

If you have any questions or concerns, please contact Silver at:
646-647-1407info@silverreg.com