Cardwell Hill Cellars has always been
committed to maintaining the strict confidentiality of personal
information regarding their clients. This long-standing policy is now
further enhanced by new rules governing privacy of consumer information
adopted by the Securities and Exchange Commission (the "SEC Rules").
Such rules, among other things, require initial and annual privacy
notices such as this Notice. The Company (sometimes referred to in this
Notice as "we" or "us") value our relationship with you and recognize
that an essential element of that relationship is your trust and
confidence that the information you share with us will be treated as
private and confidential to the extent permitted or required by law.
Set forth below in "bullet" form is a statement of practices we follow in the collection, disclosure and protection of information about you.
* Your "nonpublic personal information". As part of our business, we obtain certain information about you. Such information is defined in the SEC Rules as "nonpublic personal information".
* Sources of your "nonpublic personal information". We obtain "nonpublic personal information" about you from the following sources:
* Information provided by you in the course of forms, in orders and in correspondence; and
* Information about your transactions with us.
* Access to and protection of your nonpublic personal information. We employ procedures to safeguard your nonpublic personal information. Access to your nonpublic personal information (and the nonpublic personal information of any other client, past or present) is restricted by us to only those authorized individuals who need to know this information in order for us to provide products to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard and otherwise protect your nonpublic personal information.
* General disclosure policy. We may disclose your confidential information (or the confidential information of any other client, past or present) on a limited basis to certain nonaffiliated third parties:
* Where such disclosure is necessary to process and service transactions which you have requested or authorized or is necessary to service your account;
* Where there is not a processing disclosure, but such disclosure is permitted by law (examples being disclosures (i) to protect the confidentiality or security of our records relating to you, our services or our transactions and (ii) to protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liability); and
* Where such disclosure (i) is to nonaffiliated third parties which perform services on our behalf and (ii) is the subject of a written agreement with the nonaffiliated third parties pursuant to which such parties have agreed to keep all information furnished to them confidential and secure except as permitted by law.
You do not need to take any action as a result of this Notice. This Notice is meant to confirm our confidentiality commitment to you as part of maintaining the essential element of trust in our relationship. We value our relationship with you and strive to earn your continued trust. If you have any question or concern, you may contact Nancy or Dan Chappel.
Effective as of October 25, 2005
Cardwell Hill Cellars
11/17/2005 Scripta Communications