The policy of Investment Management of Virginia, LLC is to protect the confidentiality, integrity security of any non-public personal information of our clients and prospective clients and to prevent unauthorized access to, or the use or disclosure of such information.
IMVA’s privacy policy is as follows. “You” refers to the firm’s clients.
The Information We Collect About You. The non-public personal information we collect about you (your “Information”) comes primarily from the account applications or other forms you submit to us. We collect ongoing information regarding your account and your experiences and communication with us.
Our Disclosure Policies. We do not disclose your non-public Information to anyone, except as permitted or required by law. This may include sharing your Information with non-affiliated companies perform support services for your account or process your transactions with us. Additionally, it may include disclosing your Information pursuant to your express consent, to fulfill your instructions, or comply with applicable laws and regulations.
Our Information Security Policies. We limit access to your Information to those of our employees service providers who are involved in offering, managing, or administering the products or services we offer. We maintain physical, electronic, and procedural safeguards that are designed to comply with federal standards to guard your Information.
Information from closed accounts will be treated in the same manner as currently open accounts.
A. Staff
Specific measures that should be taken to ensure client confidentiality and privacy include:
• In general, do not disclose the identity of IMVA clients to anyone outside of IMVA.
• Shred any unneeded documents/emails that contain client information.
• Keep client documents in the proper storage area/container in IMVA’s offices.
• Do not discuss or give out client information over the phone to anyone who is not involved in management/trading of the account. The client or his/her designees are the only persons who should be given information on the account over the phone.
B. Service Providers
Service providers must agree to keep all nonpublic personal information confidential and to safeguard information to the extent required under the Gramm-Leach-Bliley Act. Service providers prohibited from viewing, accessing, or disclosing nonpublic personal information other than perform the duties for which the contract was designed.
C. Physical Safeguards
Client data should be stored as securely as possible in IMVA’s offices. Information or data that is being used should be stored as soon as is possible. Any data/information taken outside of the office should be properly safeguarded. IMVA employees who do not need access to particular client must not read/access that data. As mentioned above, any client information that is not needed should be shredded (or deleted from the “Delete File”), not simply thrown away.
D. Electronic Safeguards
IMVA will utilize the following electronic safeguards for individual computers and the firm’s network:
• Password protection for both personal computers and the network.
• Design network to monitor access.
• Utilize regular daily backup with weekly backup data stored offsite.
• Review electronic safeguard process as new options become available.
• Email files should not be considered a “safe” storage alternative. Emails that should be saved in hardcopy include: those pertinent to the management of a particular client account, relevant correspondence with a client, “Trading” emails, and any other email that would, under the Advisor’s Act, be saved in hardcopy and placed in a client’s file. In the interest of safeguarding IMVA marketing material, discussions, investment information, and electronic hardware/media, IMVA personnel should monitor their email files on a constant basis and ensure that deleted files are cleared from the “Deleted File” regularly. IMVA’s email system should not be considered private and should be used only in the context of IMVA business. The Compliance Officer has a duty to monitor IMVA’s email traffic for inappropriate uses.
E. Review and Update Procedures Annually
The Compliance Officer will review and update the Privacy Notice as necessary. The Compliance Officer is responsible for ensuring that the firm provides an annual privacy notice to all current clients.
F. Internet Web Site Privacy Policy
Information Collected on this Site and its Use. Should you visit our website and not provide any personal information, your visit will remain anonymous. The only personal information we will collect will be when you or your representative completes and submits the form requesting additional information. The information will be used exclusively to respond to your request for additional materials on our investment services or to contact you directly. Only IMVA personnel and service providers who need access to your information will be able to obtain it.
In addition, IMVA may gather information about website "traffic". IMVA may use this data to determine how many visitors have previewed our website, which pages they visit and types of operating system or browsers they utilize. IMVA may also use "cookies" (defined as a small text file stored on a computer) to analyze the site activity. IMVA will not use cookies to store any of your personal information.