Privacy Policy
Privacy Policy
Information regarding the privacy policy of Investment Management of Virginia, LLC (“We” or “IMVA”) is provided by this notice. The policy of IMVA is to protect the confidentiality, integrity and 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 except in accordance with this notice. “You” refers to our 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. Your information can include brokerage account numbers, positions held, taxpayer ID numbers, and other financial information. We also collect information regarding your account and your experiences through your communications with us. We may receive information when we provide our services to you in cooperation with an unaffiliated financial services firm.
To provide our services to you, we need current information about you and your financial position. We use this information to provide our advice and services to you and to enable this firm and our service providers to conduct your business. We also use this information to bring to your attention other services that we believe may be of interest to you.
Our Disclosure Policies. We do not disclose your non-public information to anyone, excepting what is permitted or required by law, what is required to service your account, and what is requested by you. Such permitted disclosure may include sharing your information with non-affiliated companies that 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 to comply with applicable laws and regulations.
Our Information Security Policies. We limit access to your information to those of our employees and service providers who are involved in offering, managing, or administering the products or services that we offer. We maintain physical, electronic, and procedural safeguards that are designed to comply with regulatory 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 are taken to ensure client confidentiality and privacy include:
- In general, we do not disclose the identity of IMVA clients to anyone outside of IMVA unless you have given us permission.
- Subject to governmental records retention requirements, we shred/delete any unneeded documents/emails that contain client information.
- We keep client documents in proper storage areas/containers in IMVA’s offices or other secure locations (as is required for disaster contingency planning).
- We do not discuss or give out client Information over the phone to anyone who is not a client, a designee of a client, or a person involved in the management/trading of an account, except as is required by law.
B. Service Providers
The service providers we utilize 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 are prohibited from viewing, accessing, or disclosing nonpublic personal information other than to perform the duties for which the contract was designed.
C. Physical Safeguards
We seek to assure that client data is stored as securely as possible in IMVA’s offices and secure offsite locations. Information or data that is not being used is stored as soon as is practical and possible. Any data/information taken outside of the office is required to be properly safeguarded. As mentioned above, client information that is not needed is disposed of in a secure manner.
D. Electronic Safeguards
IMVA will utilize the following electronic safeguards for individual computers and the firm’s network. To ensure the protection of Information we hold, we:
- Require our employees to use an encrypted VPN (Virtual Private Network) when connecting to our network from the outside. In addition, our employees must login and be successfully authenticated prior to any network access.
- Maintain internet security programs to limit the potential for “hackers” to access computers. Our firewall includes the following security features: IPS (Intrusion Prevention System), content filtering, web search filtering, anti-virus.anti-phishing, geo-IP based firewalling, and IPsec VPN connectivity.
- Design our network to monitor access and log events 24/7. All traffic is analyzed using an electronic security appliance which provides strong intrusion prevention coverage.
- Utilize regular daily backup with data stored offsite daily and secure email/electronic communication backup.
- Have group policies in place to prevent data from being transferred outside the network.
- Review electronic safeguard processes as new options become available and/or as new threats present themselves.
E. Review and Update Procedures Annually
The Chief Compliance Officer reviews and updates the Privacy Notice as necessary. The Chief Compliance Officer is responsible for ensuring that the firm provides an annual privacy notice to all current clients. If the Privacy Notice has not changed during the past year, distributing the Privacy Notice to current clients is not necessary.
January 2021
