The confidentiality of client information is an important concern of Harley Capital LLC (Harley Capital). We take precautions to safeguard personal client information at all times and we will remain vigilant in protecting that information. The provisions of this privacy notice will apply to former clients as well as current clients.

Harley Capital collects personal information about you that is necessary to provide financial products or services. We may obtain this information from the following sources:

Information we receive from you on account applications, forms and other materials that you provide to us, whether in writing, in person, by telephone or by any other means. This information may include your name, address, telephone number, social security number, occupation, assets and income. Information about your transactions with us or a non-affiliated third party including: account balances, payment history, electronic communications and account activity.

Information we receive from a consumer-reporting agency, such as your credit bureau reports and other information relating to your creditworthiness.

Harley Capital does not share customer non-public information with non-affiliated companies or non-exempt service providers. We will only disclose certain information about you, as permitted by law, under the following circumstances:

1. Where, we believe, in good faith that disclosure is required under law to cooperate with regulators or law enforcement authorities.
2. To consumer reporting agencies.
3. To our service providers to help us process your application or service your accounts. These service providers, in turn, are required to protect the confidentiality and security of any information we give to them and may not reuse it for any other purpose. If you prefer that we do not disclose non-public personal information about you to non-affiliated third parties, you may opt out of these disclosures, that is, you may direct us not to make these disclosures (other than disclosures permitted by law). If you wish to opt out of disclosures to non-affiliated third parties, you may call us at 212-944-1971 or submit a written request to opt out.

Harley Capital restricts access of your personal account(s) and information to those employees who require access to that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with the industry standards to safeguard your nonpublic personal information such as password protection for computerized information, access to customer information by authorized personnel and ensuring that all third-party providers have privacy policies. Third parties who have access to such personal information must agree to follow appropriate standards of security and confidentiality.

We trust that this clarifies Harley Capital position on client confidentiality and look forward to being of service to you in the future.