Privacy Policy


Why? Financial companies choose how they share your personal information. Federal laws gives consumers the right to limit some but not all information sharing. Federal law also requires UPAL to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What? The types of personal information we collect and share depend on the product or service you have with us. This information can include:

·        Name, address, phone number, social security number, tax identification number, and date of birth.

·        Account balances, and transaction history

How? All financial companies need to share client personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons UPAL chooses to share; and whether you can limit this sharing.
Reasons we can share your non-public information Does UPAL Share? Can you limit sharing?
For our everyday business purposes—

Such as to open and maintain your accounts, process your transactions, respond to legal proceedings

Yes No
For our marketing purposes—

To offer and update you on our products and services to you

Yes No
For joint marketing with other financial companies No We do not share
For our affiliates’ everyday business purposes No We do not share
For nonaffiliates to market to you   No We do not share
Opting Out Clients may request that we not disclose their non-public personal information for any reason other than for those listed above under “Reasons we can share your non-public information”. To place this request please contact us in writing at the address at the top of this policy.  If we do not receive such a request from you within thirty (30) days of opening an account, contracting for services, or receiving our annual privacy notice, we have the right to assume you do not object to the disclosure of your information for the reasons described above, until you notify us to the contrary. When you are no longer our customer, we continue to share your information as described in this notice.
What we do
How does UPAL protect my personal information? UPAL highlights the importance of confidentiality through our operating procedures, training, and this privacy policy. We and our business partners maintain electronic, physical, and procedural safeguards, in accordance with strict standards, to help protect the non-public personal information of our clients and former clients. Our agreements with our business partners require that they maintain the confidential information entrusted to them.
How does UPAL collect my personal information? ·        UPAL collects your personal information, for example, when you:

·        Open an account

·        Seek advice about your investments

·        Provide account information

·        Make deposits or withdrawals from your account

·        We also collect your personal information from others, such as other financial services companies.

Why can’t I limit all sharing? Federal law gives you the right to limit only sharing for non-affiliates to market to you. UPAL does not sell, rent, or distribute information about current or former clients or their accounts to any third parties. Specifically, we do not share information about you with companies outside our organization (non-affiliates) for them to contact you for their marketing purposes. We only share the minimum necessary information, as needed in the normal course of business, to our affiliates or companies outside our corporate family (non-affiliates) that perform services on our behalf. For example:

  • It may be necessary to provide personal identifying information to custodians, broker-dealers, or companies not affiliated with UPAL in order to open your account.
  • UPAL may have to share information with non-affiliated companies to perform services for us. This is confined to only the information the third-party needs in order to accomplish assigned responsibilities.
  • UPAL uses third-party billing, and reporting systems and we must provide non-public personal information to accomplish these back-office services.
  • We will release any information about you that you request and authorize to be released.
  • We will release information that the law permits UPAL to share with government agencies or authorized third parties under certain circumstances. We may be compelled to do so by subpoena, or to comply with certain laws.
Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies.

·        UPAL has no affiliates.

Nonaffiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies.

·        Nonaffiliates that UPAL shares information with includes Bank of Oklahoma Financial, N.A. and Charles Schwab Corporation. This also includes companies that perform services for us such as reporting and billing.

Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products and services to you.

·        UPAL does not engage in joint marketing arrangements.