Broker Check

Privacy Policy

Privacy Policy
As a registered investment advisor, Affinity Wealth Management, Inc. ® must
comply with SEC Regulation S-P, which requires registered advisors to adopt
policies and procedures to protect the nonpublic personal information of a natural
person consumers and clients and to disclose to such persons policies and
procedures for protecting that information.
In addition, our firm's policy, to the extent applicable, is to comply with the FTC's
Red Flag Rule which requires covered entities to develop and maintain an
effective client identity theft prevention program.


Background

Regulation S-P
The purpose of these Reg S-P requirements and privacy policies and procedures
is to provide administrative, technical and physical safeguards which assist
employees in maintaining the confidentiality of nonpublic personal information
("NPI") collected from the consumers and customers of an investment adviser. All
NPI, whether relating to an adviser's current or former clients, is subject to these
privacy policies and procedures. Any doubts about the confidentiality of client
information must be resolved in favor of confidentiality.
For Reg S-P purposes, NPI includes nonpublic "personally identifiable financial
information" plus any list, description or grouping of customers that is derived from
nonpublic personally identifiable financial information. Such information may
include personal financial and account information, information relating to services
performed for or transactions entered into on behalf of clients, advice provided by Affinity Wealth Management, Inc.® to clients, and data or analyses derived from such NPI.


Red Flags Rule
The Federal Trade Commission's ("FTC") FACT Act / Red Flags Rule, which became
effective 1/1/2008, covers "financial institutions" and "creditors." The Rule defines
"financial institution" as any state or federal bank or any person that directly or
indirectly holds a "transaction account" belonging to a consumer. A "creditor"
includes a broad category of businesses or organizations that regularly defer
payment for goods or services which are billed later. The FTC has clarified that any
person that provides a product or service for which the consumer pays after delivery
is a creditor under the Red Flags Rule.
Accordingly, an adviser who bills for advisory services in arrears is deemed to be a
creditor and is, therefore, a "covered entity" under the Red Flags Rule. The FACT
Act / Red Flags Rule requires covered entities to develop and maintain written
identity theft prevention programs.
In October 2009, the FTC, at the request of Congress, extended for the fourth
time the Fact Act/Red Flags Rule compliance date, from 1/1/2010 to 6/1/2010.
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Rev. 12/2014
Once again, the FTC announced that it has further delayed the compliance date
for implementation of the Red Flags Rule pursuant to the request of "Members of
Congress," while Congress considers legislation that would affect the scope of
the entities covered by the Rule. Accordingly, the revised compliance date is now
December 31, 2010. Consistent with prior compliance date delays, the FTC
indicated that the postponement is limited to the Rule. The deferment of the
compliance date does not affect other federal agencies ongoing enforcement of
corresponding identity theft program regulations.
On December 9, 2010, Congress sent the President the "Red Flag Program
Clarification Act of 2010," excluding certain providers that deliver service before
payment. On December 18, President Obama signed the bill into law. The
legislation amends the Fair Credit Reporting Act (which the FACTA amended, and
which states the penalties under the Red Flag rules) to redefine the term
"creditor." Because the definition now includes one who uses or reports to
consumer reporting agencies in connection with its transactions, and excludes one
who "advances funds...for expenses incidental to a service provided by the
creditor to that person," the definition is narrower and excludes many
professionals, including most investment advisers.
Effective July 21, 2011, authority for the Red Flags Rule was transferred from the
FTC to the SEC for firms over which the SEC has enforcement jurisdiction. While
this change in authority has no immediate impact, the SEC has stated that at some
future date it intends to conduct rulemaking that will set forth how the Red Flags
Rule may apply to the SEC-registered investment advisers and other firms subject
to its enforcement authority.
Responsibility
Victoria M. Alexitch is responsible for reviewing, maintaining and enforcing these
policies and procedures to ensure meeting Affinity Wealth Management, Inc.’s ®
client privacy goals and objectives while at a minimum ensuring compliance with
applicable federal and state laws and regulations. Victoria M. Alexitch may
recommend to the President any disciplinary or other action as appropriate.
Procedure
Affinity Wealth Management, Inc.® has adopted various procedures to implement the
firm’s policy and reviews to monitor and insure the firm’s policy is observed,
implemented properly and amended or updated, as appropriate, which include the
following:
Non-Disclosure of Client Information
Affinity Wealth Management, Inc.® maintains safeguards to comply with federal and
state standards to guard each client’s nonpublic personal information. Affinity Wealth
Management, Inc.® does not share any nonpublic personal information with any
nonaffiliated third parties, except in the following circumstances:
. As necessary to provide the service that the client has requested or
authorized, or to maintain and service the client’s account;
. As required by regulatory authorities or law enforcement officials who have
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Rev. 12/2014
jurisdiction over Affinity Wealth Management, Inc. ®, or as otherwise required
by any applicable law; and
. To the extent reasonably necessary to prevent fraud and unauthorized
transactions.
Employees are prohibited, either during or after termination of their
employment, from disclosing nonpublic personal information to any person or
entity outside Affinity Wealth Management, Inc. ®, including family members,
except under the circumstances described above. An employee is permitted to
disclose nonpublic personal information only to such other employees who
need to have access to such information to deliver our services to the client.
Security of Client Information
Affinity Wealth Management, Inc. ® restricts access to nonpublic personal
information to those employees who need to know such information to
provide services to our clients.
Any employee who is authorized to have access to nonpublic personal
information is required to keep such information in a secure compartment or
receptacle on a daily basis as of the close of business each day. All electronic
or computer files containing such information shall be password secured and
firewall protected from access by unauthorized persons. Any conversations
involving nonpublic personal information, if appropriate at all, must be
conducted by employees in private, and care must be taken to avoid any
unauthorized persons overhearing or intercepting such conversations.
Safeguarding standards encompass all aspects of Affinity Wealth
Management that affect security. This includes not just computer security
standards but also such areas as physical security and personnel
procedures. Any employee who is authorized to possess client/consumer
information for a business purpose is required to take reasonable measures
to protect against unauthorized access to or use of the information in
connection with its disposal.
 
Privacy Notices
Affinity Wealth Management, Inc. ® will provide each natural person client with
initial notice of the firm’s current policy when the client relationship is
established. Affinity Wealth Management, Inc. ® shall also provide each such
client with a new notice of the firm’s current privacy policies at least annually.
If Affinity Wealth Management, Inc. ® shares nonpublic personal information
relating to a California consumer with an affiliated company under
circumstances not covered by an exception under SB1, the firm will deliver to
each affected consumer an opportunity to opt out of such information sharing.
If, at any time, Affinity Wealth Management, Inc. ® adopts material changes to
its privacy policies, the firm shall provide each such client with a revised
notice reflecting the new privacy policies. Victoria Alexitch is responsible for
ensuring that required notices are distributed to the Affinity Wealth
Management, Inc.’s ® consumers and customers.

Changes to this policy 
Future changes may be made to our privacy policy. If you are a client, we will not make any change without first sending you a revised policy. Those changes will also be addressed on this website, which reflects the current privacy policy.