In the course of doing business with consumers, DCG may collect certain non-public, personal information about consumers and their transactions with our affiliates. For example, this information may include names, addresses, Social Security numbers, account balances and bank account information, and may be derived from account applications, other forms or transactions with DCG or its affiliates.
DCG is committed to ensuring that all non-public, personal information about our consumers is kept confidential. We will only disclose this information as permitted by law. We may share non-public, personal information with our affiliates. We may also disclose such information to unaffiliated third parties, such as: (1) government agencies in response to subpoenas or to comply with laws or regulations; (2) service providers or other firms under the direction or consent of the consumer; (3) service providers when the information is necessary for us to carry out our duties to consumers through their services; and (4) other agencies in order to protect our consumers against fraud.
We maintain physical, electronic and procedural safeguards that comply with federal standards to guard non-public, personal information. We endeavor to ensure access to consumer information is physically secure. In addition, we maintain IT security policies to ensure consumer information held in electronic format is secure, and DCG’s Compliance Officer will review those policies and procedures to ensure privacy is maintained. The Compliance Officer will also designate appropriate personnel to secure paper and computer files containing personal information pertaining to consumers. These personnel will report periodically on the status of privacy procedures to the Compliance Officer.
Information obtained through employment with DCG must be used for the proper performance of each employee’s duties. Sensitive information is only discussed within DCG on a "need-to-know" basis, and is never discussed outside the company.