Huygens may collect and retain personal information about clients from account applications or other forms, Huygens’s suitability questionnaire, Huygens’s managed account agreements, and transactions clients conduct with us.
Huygens does not disclose any personal information it collects about clients or former clients other than in connection with the servicing of client accounts or to Huygens's accountants and attorneys, or otherwise as permitted or required by law. Huygens restricts access to personal information it collects about a client to those who use that information in order to provide services to such client in the conduct of Huygens’s business. Third-party advisors to clients will have access to such information only to the extent authorized by the client.
Huygens maintains physical controls (by ensuring that no papers containing personal information are visible when not being used), electronic controls (by use of password protections on computers and certain websites) and procedural controls (using confidentiality agreements) to safeguard clients’ nonpublic personal information. This policy applies to both current and former clients.
All employees are informed of the importance of maintaining the privacy of client information, and instructed on measures to maintain privacy, including the removal of client files from desktops or working areas that cannot be locked or secured, and proper storage of client files in secured locations. Huygens uses various methods to store and archive client files and other information. All relevant third party services or contractors have been made aware of the importance Huygens places on both firm and client information security. In addition to electronic and personnel measures Huygens has implemented reasonable physical security measures at our home office location.
This PPS is given to clients at the initial signing of the client contract and mailed or emailed once annually. The CCO will document the date the PPS was mailed to each client for each year. Huygens will retain records for at least five years, or as otherwise required by applicable law. Huygens will take reasonable measures to protect against unauthorized access to or use of personal information when disposing of it.