Privacy Policy

 

At Dion Money Management, LLC (“Dion”), our most important asset is our relationship with you.  We are honored that you have entrusted us with your financial affairs, and we are committed to safeguarding the privacy of information we maintain about you.  Establishing and adhering to an effective privacy policy is an important part of that dedication.  Please take a moment to read this policy.

 

A Commitment to Your Privacy:
Dion Money Management does not share nonpublic personal information about our clients with any third party that is not directly involved in providing our investment advisory services, except as permitted by law or at a client's request.

 

Information We Collect:
Dion collects information about our clients for specific business purposes, and retains it as required by law. We safeguard information in the same manner for both former and current clients. We use the information we collect to administer client accounts, records, and assets, and to help us improve our service to clients. Sources of the information we collect include:

• Information we receive from clients on applications or other forms, such as client names, addresses, social security numbers, assets, expenses and income.
• Information about clients' total investment assets and other assets.
• Information collected through an Internet “cookie” (an information collecting device from a web server).
• Information we receive from a consumer reporting agency.

In certain circumstances, Dion may obtain login and password information for client accounts which are under our discretionary management.  Access to such information is provided only to those employees requiring the information to perform services for the particular client. 

Confidentiality and Security:
We respect the privacy of our clients and do not reveal personal or transactional information to companies that are not affiliated with us for their independent use unless the information in question is:

• Requested or authorized by the client;
• Required to complete a customer initiated transaction (such as a wire of funds or electronic transfer of funds);
• To comply with Government agencies, law enforcement officials, legal actions, as required by regulation during an audit, by statute or by court order.

All employees of Dion are required to adhere to strict standards relating to confidentiality. All information about our clients is considered private and privileged, and may be accessed only as needed to provide customer service. Internal access to this information occurs only in accordance with strictly defined security standards. Additionally, Dion employs advanced security technology to safeguard all customer data and prevent any unauthorized access from outside intrusion. Dion considers privacy, security, and service in our online operations to be just as critical as in the rest of our business. We therefore employ all of the safeguards described above, along with the following Internet-specific practices.

Website Usage:
We take the responsibility of safeguarding clients' personal information when interacting with us via the Internet very seriously. We apply the same standards discussed above in caring for clients personal information transmitted electronically. When browsing our Web site, personal information, such as one's email address, is not collected unless as submitted in a request to receive additional information from us. Some areas of our Web site require information, such as User ID and PIN Number, to enable clients to perform certain tasks (e.g. view accounts). In these cases we collect only the information necessary to provide the service required.

Our Web site provides access to client account information via direct links to Fidelity Investments and/or Charles Schwab. These companies use a variety of proven protections to maintain the security of online sessions. For example, both companies make extensive use of firewall barriers, encryption techniques and authentication procedures. Both companies use cookies and similar files that may be placed on one's hard drive for security purposes, to facilitate site navigation and to personalize the appearance of their sites.

When clients access their account through our Web site, Fidelity Investments and Charles Schwab may collect technical and navigational information, such as a computer browser type Internet protocol address, pages visited, and average time spent on the Web sites. This information may be used, for example, to alert a client to software compatibility issues, or it may be analyzed to improve the design and functionality of their Web sites. At times it may be necessary to provide customer information to parties we hire to support our products and services (such as the company that prints and mails our affiliate's newsletter and other business related materials). This information is limited to only what is required for them to perform their service. Dion Money Management requires that these companies agree to adhere to the same high standards of confidentiality that we hold, and that they maintain privacy principles that will protect and safeguard your confidential information.

This notice is being provided to you in accordance with the Securities and Exchange Commission’s rule regarding the privacy of consumer financial information (“Regulation S-P”).