Privacy Policy

Chickasaw Capital Management, LLC
Chickasaw Securities, LLC
Privacy Policy

Effective as of March 13, 2020
 

We are committed to keeping the personal information collected from our potential, current and former customers confidential and secure. The proper handling of personal information is one of our highest priorities. We want to be sure that you know why we need to collect personal information from you. We also want to explain to you our commitment to protect the information you provide to us. We never sell your information to any outside parties.

Customer Information

We collect and keep only information that is necessary for us to provide services requested by you and to administer your business with us. We may collect nonpublic personal information:

• From you when you complete an application or other form or when you disclose the information during a consultation. This includes information such as name, address, birth date, social security number, assets, income, occupation, net worth and other information deemed necessary to evaluate your financial needs.
• As a result of transactions with us, or with our affiliates or others. This could include transactions completed with us, information received from outside vendors to complete transactions or to effect planning goals.

Sharing Information

Financial companies choose how they share your personal information. Federal law gives the consumer the right to limit some but not all sharing. All financial companies need to share their customers’ personal information to run their everyday business. We only share your nonpublic personal information with non‐affiliated companies, affiliates or individuals as permitted or required by law. The types of entities or individuals with whom we might share your nonpublic personal information include your representative within our firm, a securities clearing firm, mutual funds, other product vendors, and persons in connection with compliance with legal or regulatory requirements. In the normal course of our business, we may disclose information we collect about you to companies or individuals that contract with us to perform servicing functions.

When we provide personal information to a service provider, we require these providers to agree to safeguard your information, to use the information only for the intended purpose, to perform the specific service we have requested, and to abide by applicable law. We also may be required to make disclosures to regulators who have regulatory authority over the company if certain conditions are met. We will also disclose your personal information if we reasonably believe, in good faith, that we are legally required to do so or if you consent to such disclosure. We do not provide your personally identifiable information to mailing list vendors or solicitors for any purpose.

Internet Access

We provide a website on the Internet for our company which is informational only. You should check the privacy policy for any links provided upon leaving our web site. We provide access to your securities accounts via the Internet. Your password is your private entry key into your account. You should never share it with anyone, and you should change it periodically. After you've finished accessing your securities account, don't forget to log off. This prevents someone else from accessing your account if you leave your computer and your session hasn't "timed out," or automatically shut down.

Access to Information

Only persons with a valid business reason have access to your personal information. These persons are educated on the importance of maintaining the confidentiality and security of this information. They are required to abide by our information handling practices.

Protection of Information

We maintain security standards to protect your information, whether written, spoken, or electronic. We update and test our systems to ensure the protection and integrity of information.

Disclosure of Our Privacy Policy

As a member of the financial services industry, we are sending you this Notice of Privacy Policy for informational purposes and will update and distribute it as required by law. It is also available upon request.

Opt Out Provision

If you prefer that we not disclose nonpublic personal information about you to nonaffiliated third parties, you may opt out of those disclosures, that is, you may direct us not to make those disclosures (other than disclosures permitted or required by law). If you wish to opt out of disclosures to nonaffiliated third parties, you may call the following toll‐free number: 1‐800‐743‐5410.

Former Customers

If your customer relationship with us ends, we will not destroy your personal information unless required or permitted by law. We will continue to treat your personal information in accordance with this Privacy Policy and applicable laws.

Internet Tracking Disclosure

We do not have the protocol that offers you the choice to opt‐out of internet tracking. You may reset your web browser to enable do not track functionality if your browser supports it.

Cookies

When you visit our site, we may collect information about your use of our site through “cookies”. Cookies are small bits of information transferred to your computer’s hard drive that allow us to know how often a user visits our site and the activities they are most interested in performing. We require the acceptance of cookies to enable users to take full advantage of specific services offered. We may also require you to accept cookies placed by a third party supporting this activity on our behalf.

The cookies collect certain technical and navigational information only, such as computer browser type, internet protocol address, pages visited, and average time spent on our websites. In addition, it captures the paths taken as you move from page to page (click stream activity). This information allows us to enhance your experience on the site. While we capture the paths taken as you move from page to page within our website, we do not track you over time and across third party websites and do not permit third-parties to do so on our behalf.  We also use cookies to establish and maintain a logged in connection when you are on secure sections of our website. For example, when you visit your account, the cookie allows you to navigate from page to page in a secure fashion without having to repeatedly log‐in.

Additional Disclosures for California Residents

We may collect, process or disclose certain personal information of California residents that is subject to certain provisions of the California Consumer Privacy Act of 2018, as amended (the “CCPA”). California residents have the following rights with respect to such personal information to the extent such information is subject to the provisions of the CCPA.

At or before the point of collection of a California resident’s personal information, we are required to inform such person as to the categories of personal information to be collected and the purposes for which the categories of personal information will be used. We comply with this requirement primarily by providing this disclosure statement to consumers when appropriate. We are prohibited from collecting additional categories of personal information or using personal information collected for additional purposes without providing California residents with additional notice thereof.  We will provide such additional notice, including with respect to material changes to this privacy policy, by placing an updated privacy policy on our website, by directly contacting those affected by the changes (e.g., all customers, all California-resident customers) (e.g., by United States Postal Service delivery, by electronic mail), and/or by utilizing other acceptable means of providing notice.

In addition, as a California resident, you have the right to request that we disclose the following information to you about our collection, processing and disclosure of your personal information over the past 12 months.

• The categories of personal information we have collected about you and that we have disclosed about you for a business purpose;
• The categories of sources from which the personal information is collected;
• The business or commercial purpose for collecting or selling personal information;
• The categories of third parties with whom we share personal information; and
• The specific pieces of personal information we have collected about you.
   

Though you have the right to request the business or commercial purpose for selling personal information, please note that we have never sold any consumer’s personal information, nor do we intend to do so in the future.

If you wish to submit a request for access or information pursuant to these rights, you can contact us at 901‐537‐1866 or 800‐743‐5410 or by visiting www.chickasawcap.com and clicking “Contact.” We are required to disclose and deliver to you this information free of charge within 45 days of receiving a verifiable consumer request. We may extend this time period by an additional 45 days when reasonably necessary, provided we provide you with notice of the extension within the original 45-day period. We are not required to provide requested personal information to a California resident more than twice in a 12-month period.

Each California resident also has the right to request that we delete any personal information about that person that we collect from that person. If we receive a verifiable consumer request from a California resident to delete that person’s personal information, we may delete such personal information from our records and direct any service providers to delete such personal information from their records. Please note that this right is subject to several limitations, including the following:

• The definition of “personal information” that is regulated by the CCPA and subject to the right of deletion described above does not include publicly available information from government records, information that is deidentified, or aggregated consumer information.
• We are not required to comply with a deletion request from a California resident to the extent that it is necessary for us to maintain the relevant personal information in order to comply with other legal obligations, such as our recordkeeping obligations under applicable law, and in certain other cases described in the CCPA.
• Certain provisions of the CCPA, including the provisions setting forth a California resident’s right to request the deletion of personal information, do not apply to personal information governed by certain other laws listed in the CCPA, including, as most relevant to our business, the federal Gramm-Leach-Bliley Act (Public Law 106-102), and its implementing regulations, and the California Financial Information Privacy Act (Division 1.4 (commencing with Section 4050) of the Financial Code).
   

Notwithstanding our obligations to respond to and honor consumer rights requests pursuant to the CCPA, we may extend the time period to respond to a verified consumer request by up to 90 additional days where necessary, taking into account the complexity and number of the requests, provided we inform the consumer of any such extension within 45 days of receipt of the request, together with the reasons for the delay. If requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request and notify the consumer of the reason for refusing the request.

We are prohibited from discriminating against you for exercising any of these rights, whether by denying services, by charging different prices or rates, by providing a different level or quality of services, or by suggesting that you will experience any of the foregoing.

Though you have the rights described above specific to you as a California resident, we also provide the following information regarding our collection, processing and disclosure of certain personal information about California residents with respect to our business generally:

• Where indicated below, we have collected the following categories of personal information about California residents in the preceding 12 months, and where indicated below, we have disclosed the following categories of personal information about California residents in the preceding 12 months to a third party for a business purpose:
   

• We obtain the categories of personal information listed above from the following categories of sources:
  
  • Directly from the California resident or his/her agent. For example, from documents and information that our clients provide to us in order to engage us to provide investment advisory services or that prospective clients provide to us during the process of querying and evaluating us for the purpose of providing investment advisory services.
  • Indirectly from the California resident or his/her agent. For example, through information we collect from visitors interacting with our web site or from our clients in the course of providing investment advisory services to them.
  • From third parties that interact with us in connection with the investment advisory services we provide. For example, from a custodian that holds the account for which a client has engaged us to provide investment advisory services, from a financial intermediary that has engaged us to provide investment advisory services for a client’s account or that concurrently provides investment advisory services for a client’s account, or from the administrator, custodian or transfer agent for a mutual fund which we advise and in which a consumer invests.
     
• We may use or disclose the personal information we collect for one or more of the following business purposes:
  
  • To provide you with information, products or services that you request from us.
  • To register you, at your request, for events we sponsor related to the investment advisory services we provide.
  • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  • To improve our website and present its contents to you.
  • For testing, research, analysis and product development.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
     

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

• We share personal information with the following categories of third parties:
  
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
  • Government agencies and bodies and regulatory and self-regulatory authorities as required or requested.
     

The provisions of the CCPA are complex and are subject to numerous limitations, exceptions, exemptions, carveouts and other requirements in addition to those described above. The foregoing description does not purport to be complete and is qualified in its entirety by reference to the full text of the CCPA.