Compliance Method:   

Employees of Strategic Financial Management Group, and associated companies are committed to   the provisions of the Gramm-Leach-Bliley Act (the “Privacy Act”) passed in November 1999. 

The Privacy Act requires annual delivery of our Privacy Statement (not merely an offer to send, as with Form ADV). Annually, with the First Quarter reports, clients are sent a copy of our Privacy Statement. Clients are considered to be “customers” per the definition in the Privacy Act. 

Client agreements include the Privacy Statement language to reinforce our commitment to client privacy. 

Prospects are provided our Privacy Statement as part of the marketing packet. Prospects are not “consumers,” per the Privacy Act definition, until such time as they fill out Fact Finding Data Sheets whereby they begin to disclose nonpublic personal information. The information provided in the Fact Finding Data Sheets is not disclosed to any nonaffiliated third party.

The Company maintains a hardware and software multi-level firewall, as well as a secure operating system level of security.  There is also an authentication procedure on each computer.  This is intended to protect our server from intrusion by outside parties. 

During normal business hours, our office entrance is continuously in view of employees. Outside of normal business hours, an intruder would have to break through two locked doors to obtain physical access to our files. 

Detailed investment advice and other numerical information are not sent in e‑mails, unless specifically requested. If a client requests investment advice, a telephone or office appointment is suggested, or a letter is written addressing the issue. 

Employees acknowledge the Company privacy policy by signing a Privacy Policy Acknowledgement form. 

Location:   

The master list of clients to whom the Privacy Statement has been sent each year is maintained in the archive filing area of our office, along with the list of people to whom the quarterly newsletter is mailed.

Privacy Statement:

Strategic Financial Management Group is committed to maintaining the confidentiality, integrity and security of the personal information that is entrusted to us.

The categories of nonpublic information that we collect from you may include information about your personal finances, information about your health to the extent that it is needed for the financial planning process, information about transactions between you and third parties. We use this information to help you meet your personal financial goals.

With your permission, we disclose limited information to attorneys, accountants, and mortgage lenders with whom you have established a relationship. You may opt out from our sharing information with these nonaffiliated third parties by notifying us at any time by telephone, mail, fax, email, or in person. With your permission, we share a limited amount of information about you with your brokerage firm, typically on the account application form, in order to execute securities transactions on your behalf.

The Company maintains a hardware and software multi-level firewall, as well as a secure operating system level of security.  There is also an authentication procedure on each computer.  This is intended to protect our server from intrusion by outside parties.

During normal business hours, our office entrance is continuously in view of employees. Outside of normal business hours, an intruder would have to break through two locked doors to obtain physical access to our files.

We do not provide your personal information to mailing list vendors or solicitors.

We require strict confidentiality in our agreements with unaffiliated third parties that require access to your personal information, including financial service companies, consultants, and auditors. Federal and state securities regulators may review our Company records and your personal records as permitted and required by law.

Personally identifiable information about you will be maintained while you are a client, and for the required period thereafter that records are required to be maintained by federal and state securities laws. After that time, information may be destroyed.

We will notify you in advance if our privacy policy is expected to change. We are required by law to deliver this Privacy Statement to you annually, in writing.