R.J. Dunham & Company, Inc. believes in protecting your privacy. When we collect, use and retain personal information from you, we commit to follow Safe Harbor Privacy Principles (notice, choice, onward transfer, security, data integrity, access and enforcement). We commit to train our employees to follow Safe Harbor Principles and to take disciplinary action if they do not follow the Safe Harbor Principles, and we will comply with the U.S. – EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from the European Union, as set forth at http://export.gov/safeharbor.
We make the following promises to you:
Notice. When we collect your personal information, we will not use or disclose your personal information for any purpose other than that for which it was originally collected. If our policy changes, we will give you timely and appropriate notice describing what personal information we have collected, how we will use it, and the types of third parties with whom we may share it.
Choice.We will collect only as much personal information as we need for specific, identified purposes, and we won’t use it for other purposes. If our policy changes, we promise we will give you choices about the ways we use and share your personal information, such as whether or not we may share personal information with a third party or use it for a purpose other than that for which it was originally collected, and we will respect the choices you make. For any sensitive information (medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual), you will be given an explicit choice to “opt-in” in order to permit sharing of this information with a third party or for use for a purpose other than for that which it was originally disclosed.
Onward Transfer.We will not disclose your personal information to a third party. If our policy changes, we promise that before disclosing your personal information to a third party, we will offer you the opportunity to choose whether or not we may share your personal information. If we wish to transfer information to a third party that is acting as an agent, we may do so if we first either (1) ascertain that the third party subscribes to the Principles or is subject to the Directive or another adequacy finding or (2) if the third party agrees in writing to provide at least the same level of privacy protection as is required by the relevant Principles.
Security.We will take appropriate physical, technical, and organizational measures to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration, and destruction.
Accuracy. We will collect only personal information relevant for the purposes for which it is to be used, and we will process it in a manner consistent with the purpose for which your personal information was collected or subsequently authorized by you. We will take appropriate steps to make sure the personal information in our records is accurate, complete, and current.
Access.We will provide ways for you to access your personal information, as required by law, so you can correct, amend or delete inaccuracies, except where the burden of providing access would be disproportionate to the risk to your privacy, or which would cause the rights of other persons to be violated.
In compliance with the Safe Harbor Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. European Union citizens who wish to access their information, ask questions about our privacy practices, or issue a complaint, should first contact us at:
R.J. Dunham & Company, Inc.
6111 W Plano Pkwy, Suite 2700
Plano TX 75093
Attn: Safe Harbor Compliance Representative: Judi Dunham
Phone: (469) 454-0100
We have further committed to refer unresolved privacy complaints under the U.S. – EU Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU Safe Harbor, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit the BBB EU Safe Harbor website at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
Use of protocols/analytics to assess customer/client data. By entering this site, you acknowledge and agree that Dunham+Company and/or its designees may utilize protocol or other analytics to assess customer/client data. We make reasonable efforts to have such information accord with our privacy policies though have no liability for disclosure of same by third parties with whom we maintain no contractual relationship.