Needham Capital Partners Privacy Policy
At Needham Capital Partners, we are committed to safeguarding your privacy while we help you achieve your financial objectives. This Privacy Notice describes the types of non-public information we collect
about you, the ways we safeguard the confidentiality of this information and when this information may be shared with others. In addition, this Notice explains how your personal information may be shared with other Needham
& Company, Inc. companies to make you aware of valuable products and services, and the ways that you can let us know if you prefer that your information not be shared.
The following policy applies to current and recent clients who have a brokerage account with Needham & Company, Inc.
Non-Public Information We Collect
In order to provide you with superior products and services and maintain our client relationship with you, we collect certain non-public information about you. We obtain this personal information from
the following sources:
- Applications and other forms you submit to us. We collect information such as your name, address, telephone/fax numbers, assets, income and investment objectives through these documents.
- Consumer reporting agencies. We obtain information about your creditworthiness and credit history through these sources.
- Third-party vendors. We collect background information to verify representations you have made through these companies.
Information Security
We maintain physical, electronic and procedural security measures to safeguard your non-public personal information. Access to such information is restricted to those employees who are trained in the
proper handling of client information. Third parties that provide support or marketing services on our behalf may also receive personal information about you, and we require them to adhere to our privacy standards.
Information We Disclose to Other Needham & Company Companies
In order to service and manage your account(s) effectively and to provide you with offers for products and services that you may find useful, we may disclose the non-public personal information
described above to our asset management affiliate, Needham Investment Management, LLC. Offers for products and services from our affiliates are developed under conditions designed to safeguard your privacy and we require
these companies to adhere to our privacy standards when handling your personal information.
Information We Disclose to Third Parties
On those occasions when it is necessary for us to share your personal information with non-affiliated companies, we do not disclose this information to these companies except as permitted by law. Some
instances where we may find it necessary to disclose information about you to third parties include: for servicing and processing transactions, to protect against fraud, for audit and research purposes, to respond to judicial process, law enforcement or regulatory agencies, or to perform services on our
behalf or with other financial institutions with which we have joint agreements.
When we share your non-public information with companies that perform services for us, such information may only be used for the limited purpose for which it was shared, and we do not allow these companies to
share your information with others except to fulfill that limited purpose. In addition, these companies are required to adhere to our privacy standards.
We will not make any disclosures of information to other companies who may want to sell their products or services to you.
For example, we do not sell customer lists and we will not sell your name to a catalog company.
Former Customers
Even if you are no longer a customer (or become a former customer at a future date), our Privacy Policy will continue to apply to you.
How You Can Limit Our Ability to Disclose Information to Other Needham & Company Companies
If you prefer that we do not share your non-public personal information (other than information about your transactions and experiences with us, your name, address, account number(s) or information
necessary to process your authorized transactions) with other Needham & Company companies, you may direct us not to share such information ("opt out") by:
Calling us toll free at (800) 903-3268 and asking for the Compliance Department or writing us at the following address:
Your written request should include your name, address, telephone number and account number(s) and should not be sent with any other correspondence. In order to process your request, we require that the
request be provided by you directly and not through a third party.
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