DLF collects nonpublic personal information about you from the following sources:
- Information we receive from you on applications or other forms;
- Information about your transactions with us or others; and
We do not disclose any nonpublic personal information about you to anyone, except as permitted by law. If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.
DLF restricts access to your personal and account information to those employees or 3rd parties who need to know that information to provide products or services to you. DLF maintains physical, electronic, and procedural safeguards to guard your nonpublic personal information.
The following employees will manage nonpublic information: David Lukas
The following individuals also have access to this nonpublic information: David Lukas, Scott Starkel, Klay Babin, Jared Harriman, Martiza Caro.
All Employees have passed an extensive background check before being granted access to client information.
To mitigate a possible breach of private information DLF encrypts all sensitive personal financial data on any of our local computers. We also use 3rd party services to ensure any of your information that is sent is encrypted in transit and at rest. (at rest means that any digital files that reside off-site also, utilize file encryption). The system will be tested and monitored at least annually.
To mitigate a possible breach of private information DLF will encrypt all sensitive personal financial data stored on any of our local hard drives. To accomplish this, As of January of 2019, we have replaced all windows operating systems with Macintosh which is a Unix-based operating system. DLF believes Macintosh is less likely to be exploited by hackers and has proven to be more secure. Through our extensive research, we have come to the conclusion that where a break-in occurs, the encrypted nature of data that resides on Macintosh hardware makes it virtually impossible to retrieve encrypted data. (Note the recent case where the FBI could not even hack an iPhone) All SSD in computers that have the Apple T2 Security Chip is encrypted. Additionally, if a data breach were to occur due to theft of physical hardware, any attempt to remove an SSD drive would render the hard drive useless. We also use 3rd party services to ensure any of your information that is sent is encrypted in transit and at rest. (at rest means that any digital files that reside off-site also utilize file encryption). Our current off-site service used to access client data, as well as securely transmit information to 3rd-parties involved in the setup or maintenance of your accounts is: ShareFile.com (By Citrix). The system will be tested and monitored at least annually.
DLF has taken extensive measures to safeguard the privacy and integrity of the information that it gathers, stores, and archives during its normal business practices. Computer security measures have been instituted where applicable including passwords, backups, and encryption.
All employees are informed and instructed on various security measures including the non-discussion and/or sharing of client information, always removing client files from desktops or working areas that cannot be locked or secured, and proper storage of client securities files in locked files. DLF uses various methods to store and archive client files and other information.
All third party services or contractors used have been made aware of the importance DLF places on both firm and client information security. In addition to electronic and personnel measures, DLF has implemented reasonable physical security measures at our home office location, and encouraged all remote locations, if any, to do the same to prevent unauthorized access to our facilities. Specifically, the office maintains a 24/7 alarm monitoring and has 8 monitored and recorded video surveillance cameras to prevent and deter unauthorized access to our facilities.
DLF will retain records for at least 5 years, or as otherwise required by applicable state or federal law. With respect to the disposal of nonpublic personal information, DLF will take reasonable measures to protect against unauthorized access to or use of such information in connection with its disposal.