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.).

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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.

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We are permitted by law to disclose the nonpublic personal information about our clients to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf or for joint marketing programs). These third parties are prohibited to use or share the information for any purpose. If the client decides at some point to either terminate our services or become an inactive client, we will continue to adhere to our privacy policy, as may be amended from time to time.

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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.

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Changes To Our Privacy Policy Or Relationship With The Client

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.