Privacy Policy
Dunham+Company understands the importance the community places on the preservation of confidentiality, as well as an individual's private information.
Dunham+Company is committed to the management of personal information in accordance with legislation. We do not share, sell, rent or barter any identifiable personal information to any third party without your permission.
When you visit our site, our website host makes a record of your visit and logs the following information for statistical purposes only:
- Your server address
- Your top level domain name (for example .com, .gov, .au, .uk, etc.)
- The date and time of your visit
- The pages you accessed and documents downloaded
- The type of browser you are using
U.S. – EU Safe Harbor Compliance
In compliance with our U.S. – EU Safe Harbor certification and participation in the Better Business Bureau’s EU Safe Harbor program, we adopt the following standard, comprehensive privacy policy:
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.
- Enforcement.Our published Privacy Policy shall be kept accurate, comprehensive, and shall be implemented and prominently displayed on our website.We will regularly review how we are meeting these privacy promises, provide a mechanism for recourse for non-compliance with these principles, and we will provide an independent way to resolve complaints about our privacy practices.We will also take reasonable measures to verify that the promises other businesses make to us about their privacy practices are true and that privacy practices have been implemented as presented.If we learn a business is failing to comply with their promises to follow these principles, and we will respond appropriately.
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.
2400 Dallas Parkway, Suite 400
Plano, Texas 75093
Attn: Safe Harbor Compliance Representative: Judi Dunham
Phone: (469) 454-0100
Email: judi@dunhamandcompany.com
We have further committed to refer unresolved privacy complaints under the 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, you may contact:
Council of Better Business Bureaus, Inc.
BBB EU Safe Harbor
4200 Wilson Boulevard, Suite 800
Arlington, VA 22203
Phone: 703-276-0100
Web: www.us.bbb.org
Email: eusafeharbor@council.bbb.org
