Charlson & Wilson

INFORMATION SECURITY AND PRIVACY POLICY

    Title V of the Gramm-Leach-Bliley Act (GLBA) and the laws of the State of Kansas generally prohibit financial institutions, directly or through any affiliate, from sharing nonpublic personal information (NPI) about our customers with a nonaffiliated third party unless the institution provides the customer with a notice of its privacy policies and practices, such as the type of information that it collects and the categories of persons or entities to whom that information may be disclosed.
    • OUR PRIVACY POLICIES AND PRACTICES

    1. Information we collect and sources from which we collect it:

      We may collect nonpublic personal information about our customers from the following sources:

      • Information on applications, legal documents, and affidavits necessary to issue title insurance policies and/or process the sale of property or to refinance a mortgage loan. Examples of such nonpublic personal information include, but are not limited to, date of birth, social security numbers, sale prices, title insurance policy numbers and amounts of insurance, bank account numbers, credit card numbers, loan numbers, payoff amounts, sale contract information, addresses and phone numbers, and IRS Forms 1099S.

      • Information about transactions we obtain from our existing files.

      • Information we receive from others involved in transactions, such as lenders or real estate agents/brokers.

    2. Information we disclose to third parties:

      We request information for our own legitimate business purposes and not for the benefit of any nonaffiliated party. Therefore, we will not release information to nonaffiliated parties, except: (1) as necessary for us to provide the product or service requested of us; or (2) as permitted by law.

      We do not disclose any nonpublic personal information to anyone for any purpose that is not specifically permitted by law.

      We may, however, store such information indefinitely, including the period after which any customer relationship has ceased. Such information may be used for any internal purpose, such as quality control efforts or customer analysis.

    3. Our practices regarding information confidentiality and security:

      We will use our best efforts to ensure that no unauthorized parties have access to any information. We restrict access to nonpublic personal information to those employees who need to know that information to provide products and services requested by our customers. We will use our best efforts to train and oversee our employees to ensure that information will be handled responsibly and in accordance with this Privacy Policy. We maintain physical, electronic and procedural safeguards that comply with federal and state regulations to guard nonpublic personal information.

    4. Specific practices to safeguard information:

      The Company maintains a clean desk policy, with all non-public information being securely located in locked cabinets or rooms during non-business hours;

      Individual company computers are password protected, with only the employee and authorized supervisors having access to the passwords;

      The Company prohibits employee use of company computers for personal use and prohibits the personal use of removable media (i.e., thumb drives, floppy disks, etc.);

      Employees are prohibited from disclosing information to a person or entity not a party to the transaction without a written request from a party authorized to obtain the information requested;

      The Company conducts NPI training sessions for employees on a quarterly basis;

      Employees are instructed to use only secure delivery methods when transmitting NPI, such as facsimile, hand-delivery and encrypted e-mail; and Off-site information is stored with and NPI documents no longer needed are destroyed by Underground Vaults & Storage, Inc., a regionally recognized document storage/destruction company which certifies maintenance of document and privacy security.

    5. Our policy regarding dispute resolution:

      Any controversy or claim arising out of or relating to our Privacy Policy, or the breach thereof, shall be settled by arbitration in accordance with the rules of the American Arbitration Association, and judgment upon the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof.