Wilbanks, Smith & Thomas Asset Management, LLC, (“WST”), respects every client’s right to privacy and we remain dedicated to protecting the confidentiality of the information entrusted to us by our clients.

Client Information

The information WST collects is limited to that which may be useful as we conduct our business and provide services to clients; protect and administer client accounts; comply with all regulatory laws and regulations; obtain an understanding of a client’s financial needs so that we may provide them with the highest quality of service. WST may collect nonpublic, personal information about its clients from the following sources:

• Information provided by clients on applications or other forms used to establish and maintain an account, such as assets and income;
• Information we have obtained at a client’s request;
• Information we may receive from public records and market research;
• Transactional reports, trade confirms, activity reports or statements regarding a client’s account asset information from a broker, bank or other financial institution generated in the servicing of the account;
• Financial or asset related information that we may receive from third parties with respect to a client’s account.

Shared Information

WST does not sell information or client lists to third parties nor do we share information about any clients or former clients other than to provide investment management services to our client accounts. We will disclose information in very limited instances as permitted by law, including:

Disclosures to companies or affiliates who perform services for WST on a client’s behalf and who are obligated to keep any information we provide them strictly confidential such as vendors we engage to facilitate account reviews; technology consultants who assist WST in maintaining its computer systems; and client brokers and account custodians.

Disclosures to companies as permitted by law, including those necessary to service and process a client’s account transactions; disclosures in connection with subpoenas or other legal processes; disclosures as part of fraud investigations; disclosures in connection with audits and examinations; and disclosures pursuant to a client’s authorization or consent.

WST may also mail to its clients, periodic account statements, for accounts with a common mailing address in a single envelope for convenience. This may include other family or related accounts with the same mailing address and is done at the request of the client.

WST has adopted the following internal policies and procedures to maintain both physical and electronic safeguards in accordance with federal guidelines and legal standards, protecting both client and former client’s nonpublic, personal information from unauthorized disclosure:

• WST employees are bound by our Code of Ethics and access to client information will be restricted to legitimate business purposes only;
• WST continues to educate its employees on the importance of client confidentiality and requires them to sign a client confidentiality agreement;
• WST employees are required to shut down computers each night and all have password protected access;
• WST utilizes a service for shredding internal documents that contain confidential information;
• Office suite doors are locked after 5pm daily with 24 hour security in the building;
• Client records are maintained in a designated, secured room in file cabinets and/or in electronic format on our network;
• WST computer network servers are maintained in a secure room with restricted access;
• WST maintains a firewall restricting the inflow of traffic on our connection to the internet;
• No client information is posted on our website;
• All user’s computers lock automatically after 15 minutes of inactivity;
• Nightly network scans keep computers free of viruses or worms on the network.

This Privacy Notice is subject to revisions and you may request a copy of WST’s current Notice by contacting our office.