Needham & Company, LLC is committed to safeguarding your privacy. This Privacy Statement describes the types of non-public personal 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 Privacy Statement explains how your personal information may be shared with Needham & Company, LLC affiliates to make you aware of valuable products and services, and the ways that you can let us know if you prefer that your non-public personal information not be shared. By using this website, you consent to the policies and practices described in this Privacy Statement.
The following policy applies to users of this website, including clients who have a brokerage account with Needham & Company, LLC
1. Non-Public Personal Information We Collect
In order to provide you with superior products and services and to maintain our relationships with our clients, we may collect certain non-public personal information about you. We obtain this non-public personal information from varying sources, including the following:
(1) Applications forms and other communications. We collect information such as your name, address, telephone/fax numbers, assets, income and investment objectives through these documents.
(2) Consumer reporting agencies. We obtain information about your creditworthiness and credit history through these sources.
(3) Third-party vendors. We collect background information from various outside sources to verify representations you have made to those sources or us.
2. Information Security
We maintain physical, electronic and procedural security measures to safeguard your non-public personal information. Access to such information is restricted to employees who are trained in the proper handling of personal information. Third parties that provide support or marketing services on our behalf may also have access to the non-public personal information we collect about you while carrying out these services, but are required not to share that information with any other third party. While we employ reasonable measures to protect personal information, we cannot guarantee that unauthorized third parties will not defeat those measures or use non-public personal information for improper purposes.
3. Information We May Disclose to Our Affiliates
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 affiliates, including 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 non-public personal information. Please see Section 6 for instructions on how you can limit our ability to disclose non-public personal information about you.
4. Information We May 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: in connection with servicing and processing transactions, to protect against fraud, for audit and research purposes, to respond to judicial process, law enforcement or regulatory agencies, to perform other services on our behalf, to protect our rights or property and the rights of our clients, or to prevent a crime or protect national security.
We may disclose all of the information we collect, as described above to companies that perform marketing services on our behalf or to other financial institutions with which we have joint agreements. When we share your non-public personal information with other parties that perform services for us, we require that such information only be used for the limited purpose for which it was shared and that those parties not share your information with others except to fulfill that limited purpose.
We do not make any disclosures of non-public personal information to other companies for the purpose of marketing 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.
We may disclose and transfer personal information to a third party who acquires all or a substantial portion of Needham & Company, LLC's business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets. In addition, in the event Needham & Company, LLC becomes the subject of a bankruptcy proceeding, whether voluntary or involuntary, we or our trustee in bankruptcy may sell, license or otherwise dispose of such information in a transaction approved by the bankruptcy court.
5. Former Customers
Even if you are no longer a customer (or become a former customer at a future date), our Privacy Statement will continue to apply to the non-public personal information we collected about you.
6. How You Can Limit Our Ability to Disclose Non-Public Personal Information to Our Affiliates
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 our affiliates, 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:
Needham & Company, LLC
Attn: Compliance/ Privacy Policy
445 Park Ave, 15th Floor
New York, NY 10022
Your written request should state in detail the nature of your request, 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.
7. How You Can Update Your Personal Information
You may update personal information that you submitted to us by contacting us using the methods described above.
8. Links to Other Websites
Needham & Company, LLC does not take responsibility for collection of personal information via other websites for which a link is provided on this website. You should refer to the privacy statements for those websites.
9. Children
This website is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13.
10. Changes to Privacy Statement
We reserve the right to make changes to this policy.
4/6/05
