Privacy Notice

Protecting your privacy is a priority of G.Cefalu & Bro., ( “G.Cefalu & Bro.”, “we”, “our” or “us” ), and its affiliates (“Affiliates”). We value the confidence you have placed in us and are committed to ensuring that your client information is safeguarded. This Privacy Notice (“Notice”) explains how we collect, share, and protect your personal information. This Notice also gives you valuable information on the choices you have about how we use your personal information. Please read this Notice carefully to understand what we do.

Information We Collect About You

We may collect the following types of nonpublic personal information about you from the following sources: (1) information we receive from you on applications or other forms when you open an account, register for one of our products or services, or accept a promotional offer for a product or service from us or companies related to us through common ownership or control (“Affiliates”) (such as your name, address, Social Security number, phone number, e-mail address, assets, income, business information, licensing, and motor vehicle information); (2) information about your transactions with us, Affiliates or others (such as your account balance, payment history, parties to transactions, health care information, claims history, and use of products and services); and (3) information we receive from a consumer reporting agency and other third parties (such as your credit worthiness and credit history). We call all of the personal information described above and elsewhere in this Notice “Client Information.”

Confidentiality and Security of Client Information

We restrict access to your nonpublic Client Information to persons who need to know that information. We maintain physical, electronic, and procedural safeguards to protect your Client Information.

Use of Client Information

We use Client Information for: (1) our everyday business purposes, such as processing transactions, maintaining your account, reporting to credit bureaus, verifying your identity, and fulfilling legal and regulatory obligations; (2) our marketing purposes of us and our Affiliates, namely to offer our products and services to you; and (3) joint marketing with our Affiliates and other companies. Upon your written request, we will provide you with a summary of the Client Information we have collected about you. We will not send you information collected in expectation, or in connection with, any claim, civil or criminal proceeding. If you feel your Client Information in our files is incorrect or incomplete, we will review it. If we agree, we will make your necessary corrections, and, upon request, inform anyone who received such information from us in the past two years. If we do not agree, you may give us a brief statement that we will include with future disclosures and send to anyone who received the information from us in the past two years.

Disclosure of Client Information to Affiliates

We may share Client Information with our Affiliates in order to (1) service your account; and (2) offer our products and services to you. The Client Information we share with Affiliates includes identification and contact information and general information about your transactions and experiences with us. We do not share information relating to your physical or mental health or the provision of health care to you (“Health Information”) that we collect or investigative consumer reports that we obtain except to underwrite or administer your insurance policy or related claims or to administer your annuity contract, as required by law or as authorized by you. You have a choice about the offers that are sent to you by our Affiliates as explained in Opt-Out Choice A below.

Disclosure of Client Information to Outside Companies

We may share Client Information with outside companies in limited circumstances: (1) to help us process transactions for your account; (2) to service your account or perform other business functions on our behalf, such as mail and print vendors; (3) when disclosure is required or permitted by law. For example, we may be required to disclose Client Information to cooperate with law enforcement and regulatory authorities, to resolve client disputes, and to perform credit checks and authentication procedures to prevent fraud; and (4) when we enter into a joint marketing agreement with another financial institution to provide products and services such as insurance that may be beneficial to you. When we share Client Information with outside companies or third parties, we require them to safeguard this information and only use it for the agreed upon purpose. Additionally, we may use Client Information to send you marketing offers on behalf of selected outside companies for products that they sell. You may direct us not to use your Client Information for this purpose as described in Opt-Out Choice B below.

You Have Choices About How We Use and Disclose Client Information

You have choices about offers that may be sent to you. Your opt-out choices and how to opt-out are explained below. A. Offers for Products and Services of Our Affiliates (Opt-Out Choice A) G.Cefalu & Bro. and its Affiliates provide a wide range of services, including produce distribution, purchasing, grower relationships and seafood distribution. We may disclose certain Client Information to our Affiliates in order to service your accounts and to develop and send you offers for their products and services. You may opt-out of receiving separate marketing offers from our Affiliates. If you choose Opt-Out Choice A, we may still share information with our Affiliates as permitted by law, but our Affiliates will not use this information to send you marketing offers. To opt-out from receiving marketing offers from our Affiliates,r fill out and return the attached form and check the Opt-Out Choice A box. If you cal lus, you will be asked for your name and customer verification information so that we can correctly record your opt-out choices. B. Offers for Products and Services of Other Companies (Opt-Out Choice B) You may direct us not to use your Client Information for the purpose of sending you offers for products and services on behalf of outside companies, unless otherwise authorized by you, by selecting Opt-Out Choice B. To opt-out of receiving marketing offers from us on behalf of outside companies, call us at 1- (410) 755 1733 or fill out and return the attached form and check the Opt-Out Choice B box. If you call the toll-free number, you will be asked for your name and customer verification information so that we can correctly record your opt-out choice.

Additional State Opt-Out Information

In states where additional notification is required before you can provide an effective opt-out, we will contact you separately regarding your opt-out choices. If any accounts with us have a California mailing address, California law requires that we not share Client Information with nonaffiliated third parties except as permitted by California law, such as with your consent, to service your account, or to other financial institutions with which we have joint marketing agreements. If any of your insurance or annuity accounts with us has a New Mexico Billing address, we will automatically treat all of your accounts as if you chose Opt-Out Choice B as described in this Notice.

Former Clients

If you close an account, your account becomes inactive, or you are no longer a client, we will continue to treat and safeguard your Client Information as described in this Notice.


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