Privacy Policy

Ferguson Wellman Capital Management, Inc. is a registered investment adviser that specializes in personalized asset management for its individual and family clients, as well as clients for the firm’s divisions, West Bearing Investments and Octavia Group. In compliance with the Securities and Exchange Commission’s Privacy Regulations for Investment Advisers, we are required to provide existing customers with this privacy notice. In accordance with that regulation, the material below describes how we collect, use and safeguard the information that is provided to us.

The Collection of Information

Ferguson Wellman collects and maintains your personal information so that we may provide investment management services to you. We collect your nonpublic information through various methods, including but not limited to the examples provided below:

• Information received from you on contracts, account applications or other forms (address, Social Security number, and certain financial information)
• Information regarding your transactions with us (account statements, transaction reports, trade tickets)
• Information received from you to establish and manage your relationship with us (photo IDs, trust documents)
• Information received from you to access personal account information online (email address, password)
• Electronic correspondence and communications sent to Ferguson Wellman and its agents
• Information collected may vary depending on the type of account opened

Information Sharing

Ferguson Wellman may disclose nonpublic personal information about our clients as necessary to conduct business or where disclosure is required by law:

• Third parties that administer and support our transactions (brokers, custodians)
• Third parties retained by the client for services on behalf of the client (accountants, attorneys, administrators and financial planners)
• Third parties that perform services on our behalf (outside mail houses, external service providers, consultants, and technology providers, including providers of data processing and analytical tools)

Confidentiality

Ferguson Wellman restricts access to nonpublic information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards to guard your nonpublic personal information. In order to maintain your complete privacy we will not disclose your personal information to anyone unless directed by you, required by law or as necessary to provide services to you.
We may utilize technology tools, including those incorporating artificial intelligence or machine learning, to support our operations, analysis and enhance the services we provide to clients. When we use these tools, they are subject to our confidentiality and information security requirements. We do not permit client information to be used by these providers to train or improve their models, and we take reasonable steps to ensure that such information is used solely for purposes of providing services to Ferguson Wellman and its clients.