Privacy and Routing Policies

Privacy and Routing Policies

Dominion Investor Services, Inc. and Dominion Portfolio Management, Inc. (Dominion) respect the privacy of our clients, and we are committed to maintaining the confidentiality of any personal or financial information that we may collect. Dominion has always considered the safeguarding of sensitive information to be a high priority. This notice describes the types of client information we collect and under what circumstances we may share it.

Client Information that We Collect

Dominion collects only the information about you that is relevant to the establishment and maintenance of your account as the law (or regulations) requires or allows us to collect.

Dominion's Policy

We do not share or redistribute our clients' (customers or consumers) personal information other than as necessary to service their accounts. Under no circumstances does Dominion sell or rent clients' (customers or consumers) personal information. This policy continues in effect for former clients.

Information about You is collected from the Following Sources

We retain the personal information from your application or contract that you provide for securities brokerage or asset management purposes so that your account may be serviced properly. This information includes: names, address, social security number, birth date, telephone numbers, marital status, investment objectives, annual income, investment experience, employment, number of dependents and, in the case of some insurance applications, smoking status, driving status, driver's license number, insurance history, medical history, and physician information.

Transaction Information

Whenever you make a transaction in any of your accounts, regardless of account type or method of order entry, we maintain a record of the transaction including the security, the date, and the amount purchased, price, dollar amount of the transaction, and any other information that may be pertinent to the transaction.

We collect financial needs profiles, risk tolerance analysis, and other suitability information. Depending upon the type of services that are to be provided, you may be (or may have been) asked to fill out one or all of the above in addition to the standard application. This information is requested to assist in determining more detailed aspects of suitability when the products or services being considered require a more in-depth profile to determine whether they are appropriate and, if so, to add valuable insights as to how to best serve you.

Information other than that provided on the standard application may include: familiarity with strategies, investment constraints, level of financial sophistication, retirement goals, estate transfer information, financial structure information (assets, liability, liquidity, etc.), insurance coverage, your opinions on risk vs. reward, and any other information that you may choose to provide your representative to help produce an accurate profile of your needs.

We receive information from verification services and consumer reporting agencies to help ensure the accuracy of application data, or to assess credit worthiness if you apply for credit products.

With your consent, information is also received from other institutions (for example, if you are transferring an account).

Information that We Share

Dominion restricts access to your information to those who require that access in order to provide products and services to you. We may share the personal information that we collect about our customers, prospects, or former customers with:

  • Affiliates
  • Unaffiliated service providers (example: fulfillment companies and securities clearing houses)
  • Government Agencies and Law Enforcement Officials (example: tax reporting or court order)
  • Other organizations, as permitted by law that protect your privacy (example: fraud prevention efforts)
  • Regulators
  • Other investment organizations, with your consent and instructions (example: a mutual fund company where you have an account)
  • Other service organizations, with your consent (example: if you request personalized performance reporting)

How We Protect Your Information

Dominion has always safeguarded our clients' information. We restrict access to your information physically and electronically. Hilltop Securities, our clearing firm, provides our electronic safeguards. Their systems are designed with extensive information protection controls in keeping with industry standards. These systems are regularly adapted to respond to changing requirements and advances in technology.

Order Routing

Dominion routes all orders to Hilltop Securities (HTS) via their proprietary order entry systems. Upon request, HTS will provide the routing detail on individual transactions. In order to request this information, please contact your Registered Representative or Dominion's Customer Service.

Payment for Order Flow

Dominion does not receive payment for Order Flow.