General

Highland has adopted certain procedures designed to maintain and secure the non-public personal information of its clients from inappropriate disclosure to third parties. The policy is designed to meet the standards set forth in the federal regulations.

We are committed to keeping personal information collected from potential, current and former clients confidential and secure. The proper handling of personal information is one of our highest priorities. The Company never sells information relating to its clients to any outside third parties.

The Privacy Policy will be provided to customers initially upon establishing an account and annually or upon request.

Nonpublic Information

We collect and keep only information that is necessary for us to provide the services requested by our clients and to administer clients’ business with the Company.

We may collect non-public personal information from clients or potential clients:

  • From clients when they complete an application or other form, as well as through written and electronic correspondence and telephone contacts. This includes information such as name, address, social security number, assets, income, net worth, copies of financial documents and other information deemed necessary to evaluate the Client’s financial needs.
  • As a result of transactions with the Company, its affiliates or others. This could include transactions completed with the Company or information received from outside vendors to complete transactions or to effect financial goals.

Sharing Nonpublic Information

In the normal course of business, the Company may share the non-public personal information of its clients with non-affiliated companies or individuals (i) as permitted by law and as required to provide services to our clients, such as with representatives within the Company, administrators, securities clearing firms, mutual fund companies, insurance companies and other financial services providers, or (ii) to comply with legal or regulatory requirements. The Company may also disclose non-public personal information to another financial services provider in connection with the transfer of an account to such financial services provider. Further, in the normal course of our business, the Company may disclose information it collects about clients to companies or individuals that contract with the Company to perform servicing functions such as:

  1. Record keeping
  2. Computer-related services
  3. Good faith disclosure to regulators who have regulatory authority over the Company