In the course of conducting business with Guzman & Company (“Guzman”), customers typically share certain personal, financial, and other sensitive information with Guzman and its affiliates. Guzman treats this information as confidential and recognizes the importance of protecting it. This document explains what information Guzman collects, how it protects that information, and under what circumstances it will share that information.

Guzman may collect nonpublic personal information about clients from the following sources:

• information clients directly communicate to Guzman;
• information about client transactions with Guzman, its affiliates, or others;
• information Guzman receives from third parties providing services to Guzman.

The types of personal information Guzman collects depend on the nature of the product or service Guzman provides. This information might include the following: Social Security (or other identification) number and income, account balances and payment history.

Guzman does not sell information about current or former customers to any third parties, and does not disclose it to third parties unless such disclosure is permitted by law. Guzman will disclose such information when necessary for it to conduct business, including by processing transactions, servicing accounts, or responding to court orders or legal investigations. Guzman may also share information with one of its affiliated companies in the course of providing or offering products and services.

Guzman maintains electronic, physical, and procedural safeguards to protect customers’ personal and financial information. Within Guzman, access to such information is limited to those who need it to perform their jobs, such as servicing customer accounts, resolving inquiries, or informing the customer of new products or services. Internal policies and procedures restrict the use of customer information and require that it be held in strict confidence.

The Guzman Compliance Department can be reached at 305.374.3600 or in writing to Guzman & Company; 101 Aragon Avenue; Coral Gables, Florida 33133 regarding questions, concerns, or complaints.