Asgard is a FINRA broker-dealer. We will make our Investors and their Investors aware of the Firm’s policies regarding the Firm’s use of the information provided to us when establishing or while maintaining a relationship with us.
Asgard does not sell personal information about its investors to anyone. Asgard will not share personal information about the Firm’s investors with other companies unless the Firm needs to share the information in order to provide a product or service a customer has requested. Unless Asgard tells investors otherwise, these other companies do not have the right to use investors’ personal information obtained from the Firm in any manner beyond what is required to provide a investors’ requested product or service. The firm limits the collection of personal information to what is necessary to administer Asgard’s business and to deliver the Firm’s products and services to Asgard’s investors. It is sometimes necessary in the conduct of the Firm’s business that the Firm shares information with Asgard’s affiliates.
Asgard does reserve the right to disclose or report personal information in limited circumstances where the Firm believes in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities, to perform necessary credit checks or collect or report debts owed to us, to protect Asgard’s rights or property, or upon reasonable request by the sponsor or provider of a product in which you have chosen to invest. Listed below is the information the Firm does collect and how Asgard uses that information:
Forms you may complete to interact with the Firm such as:
- new account forms
- agreements and contracts
- tax returns and pay stubs
- questionnaires and miscellaneous forms.
These forms may request personal information such as your e-mail address, telephone number, mailing address, financial information, employment information, investment objectives and financial needs, and pension information for example.
How Asgard uses this information
Your personal information is generally maintained by your name in Asgard’s files. Your personal information is utilized strictly for the purpose of conducting business with you. At no time does Asgard sell your information or share it unless it is necessary to conduct business with you. On occasion, Asgard’s investors’ service providerssuch as accountants, attorneys, etc. may request non-public information about them. Asgard will upon request and upon notification to the Firm’s clients supply such provider with such information.
Protection of Client Information
Our firm’s policies require that employees with access to confidential investor information may not use or disclose the information except for business use. Access to client information is available to employees on a “need-to-know” basis only and is restricted to certain employees, representatives and agents with a business reason for access to such information. Asgard safeguards information according to established security standards and procedures and train Asgard’s employees and representatives to understand and comply with these protections.
One significant concern that has driven recent regulations regarding the confidentiality and privacy of customer information is identity theft. While some of the recent, high-profile cases of identity theft involve unauthorized access to electronic information, some recent reports indicate that the majority of identity theft cases are still committed with information obtained offline. Asgard’s procedures do not focus solely on the use of electronic information, but also address the proper use and destruction of paper documents (including, of course, consumer report information under the recent amendments to Regulation S-P) that could raise privacy concerns.
As the Firm updates its technology and use new and different methods of communication, whether through the use of wireless technology or allowing employees to work remotely, we will consider whether these methods necessitate updates or changes in our policies and procedures. We will consider the following, at a minimum:
- whether our existing policies and procedures adequately address
the technology currently in use;
- whether we have taken appropriate technological precautions to protect customer information;
- whether we are providing adequate training to its employees regarding the use of available technology and the steps employees should take to ensure that customer records and information are kept confidential; and
- whether we are conducting, or should conduct, periodic audits to detect potential vulnerabilities in its systems and to ensure that its systems are, in practice, protecting customer records and information from unauthorized access.
The use of new technologies can benefit the Firm, our employees, and investors; however, these new technologies can also present risks that we must consider and address appropriately. In some instances, the appropriate way to deal with these risks is not only through technological solutions but may also involve changes to our training regimen and/or to our policies and procedures. We will consider whether the adoption of new technologies would necessitate changes in its compliance policies and procedures or systems before implementation so that issues can be identified and addressed in a timely way and problems can be avoided.
The Firm is aware of its obligation to protect confidential customer records and information relative to the use of WiFi technology or other remote access to customer account information. Currently, the Firm’s associated persons do not have access to customer accounts through WiFi or other remote technology; however, in the event such access is granted in the future, the Firm will take steps to determine whether the adoption of new technologies would necessitate changes in its compliance policies and procedures or systems before implementation so that issues can be identified and addressed in a timely way and problems can be avoided. Consumer information will be shredded rather than discarded when no longer necessary to be maintained by the Firm
E-mail at Asgard
Asgard may rely on E-mail as a means of communication between the Firm and its clients.
Changes to Firm Privacy Policies
From time to time the Firm may update its privacy policies. All new investors will receive the Firm’s most current private policy upon entering into an agreement or opening an account with the Firm. All investors will be provided with the Firm’s most current privacy policies at leastannually.
You may contact the Firm by telephone at:
Or you may also communicate with the Firm in writing at:
Asgard Securities, LLC
12 East 49th Street, 11th Floor
New York, NY 10017
Or you may send emails to Asgard’s President at: