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Harman, Rogowski, & Associates (“Harman Rogowski”) maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”).  Through this policy and its underlying procedures, Harman Rogowski attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.  

It is the policy of Harman Rogowski to restrict access to and/or the sharing of all current and former clients’ information (i.e., information and records pertaining to personal background [including social security number and address], investment objectives, financial situation, financial planning issues, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in furtherance of the client’s engagement of Harman Rogowski.  

Harman Rogowski shall disclose, as necessary, the client’s information: (1) to unaffiliated service providers and vendors  in furtherance of establishing, maintaining, and reporting on the client’s Harman Rogowski relationship (i.e., broker-dealer, account custodian, record keeper, technology, performance reporting, customer relationship  management software [CRM], proxy voting, insurance, independent managers, sub-advisers, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with applicable federal and/or state privacy regulations.

However, Harman Rogowski does not, and shall not, disclose or share information with any affiliated or nonaffiliated persons, entities or service providers for marketing or any other purposes or reasons not referenced above.

ANY QUESTIONS OR CONCERNS: Should you have any questions regarding the above, please contact (214) 556-3255.


Pursuant to applicable federal and/or state privacy regulations, Harman, Rogowski, & Associates (referred to as “Harman Rogowski”) is a financial institution that has determined to keep confidential nonpublic personal information about each Harman Rogowski client.        

Nonpublic personal information is defined to mean personally identifiable financial information that is provided by a consumer to a financial institution, results from any transaction with the consumer or any service performed for the consumer, or is otherwise obtained by the financial institution.  

Personally identifiable financial information means any information: (1) a consumer provides to a financial institution to obtain a financial product or service; (2) about a consumer resulting from any transaction involving a financial product or service between a financial institution and a consumer; or (3) a financial institution otherwise obtains about a consumer in connection with providing a financial product or service to that consumer.

Attached hereto and made a part hereof is a copy of Harman Rogowski’s Privacy Notice that is to be distributed by Harman Rogowski: (1) initially: (a) to each existing Harman Rogowski client; and (b) to each new client prior to or at the time of establishing a “customer relationship” with Harman Rogowski; and (2) annually thereafter for as long as the client maintains its relationship with Harman Rogowski (however, per the SEC, unless there are material changes, Harman Rogowski is no longer required to provide the Privacy Notice annually. Harman Rogowski may determine to cease providing the Privacy Notice on an annual basis).  

The purpose of Harman Rogowski’s Privacy Notice, Privacy Policy as well as its underlying procedures is to protect the confidentiality and security of its clients’ nonpublic personal information.  The categories of nonpublic personal information that Harman Rogowski collects from a client depend upon the scope of the client engagement.  It may include information about the client’s personal finances, information about the client’s health to the extent that it is needed for the planning process, information about transactions between the client and third parties, and information from consumer reporting agencies. Harman Rogowski has instituted certain technical, administrative and physical safeguards through which Harman Rogowski seeks to protect this nonpublic personal information about current and former clients from unauthorized use and access.  First, technical procedures are used in order to limit the accessibility and exposure of client information contained in electronic form. Second, administrative procedures are used in order to control the number and type of employees, affiliated and nonaffiliated persons, to whom customer information is accessible.  Third, physical safeguards have been established to prevent access to client information contained in hard-copy form.  As illustrated above, Harman Rogowski realizes the importance of information confidentiality and security, and emphasizes practices which are aimed at achieving those goals