We have adopted this policy with recognition that protecting the privacy and security of the personal information we obtain about our clients is an important responsibility. We also know that our clients expect us to service their accounts in an accurate and efficient manner. To do so, we must collect and maintain certain personal information about our clients. We want our clients to know what information we collect and how we use and safeguard that information.
What Information We Collect
We collect certain nonpublic personal identifying information about our clients (such as name, address, social security number, etc.) from information that the client provides on applications or other forms as well as communications (electronic, telephone, written, or in person) with the client or authorized representatives (such as attorneys, accountants, etc.). We also collect information about brokerage accounts and transactions (such as purchases, sales, account balances, inquiries, etc.).
What Information We Disclose
We do not disclose the nonpublic personal information we collect about our customers to anyone except:
(i) in furtherance of our business relationship and then only to those persons necessary to effect the transactions and provide the services that the client authorizes (such as broker-dealers, custodians, independent managers, etc.);
(ii) to persons assessing our compliance with industry standards (e.g. professional licensing authorities, etc.);
(iii) our attorneys, accountants, and auditors; or
(iv) as otherwise provided by law.
Security of Client Information
We restrict access to client nonpublic personal information to those employees who need to know that information to service the accounts. We maintain physical, electronic, and procedural safeguards that comply with applicable federal or state standards to protect client personal information.
Our policy about obtaining and disclosing information may change from time to time. We will provide the client notice of any material change to this policy before we implement the change.