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We are concerned about your privacy. We have always been committed to maintaining the confidentiality, integrity and security of personal information entrusted to us by our clients. We are proud of our privacy practices, and we want you to know how we protect your information and how we use it to service your account. We do not sell your information to third parties, and we disclose your personal information only as necessary to provide the advisory services that you request and that you have come to expect from us. This summary of our practices is provided for your information. You do not need to take any action as a result of this notice unless you have any questions or concerns.
 
What information do we collect from and about you?
To conduct our business, we may collect nonpublic personal information about you:
  • From applications, questionnaires or other forms, such as name, address, telephone number, email address, Social Security number, birth date, assets and income, employment status, dependent information, current investments and investment experience
  • From prior transactional activity in your account, such as trading history, positions and balances
  • From other sources with your consent or with the consent of your representative
 
How do we protect the confidentiality and security of your nonpublic personal information?
We have always considered the protection of sensitive information to be a sound business practice and a foundation of client trust. We employ information protection controls in keeping with industry standards and practice, and we adapt these physical, electronic, and procedural safeguards to respond to changing requirements and advances in technology. We restrict access to nonpublic personal information about you to those employees who require access to that information in order to provide our services or to otherwise conduct our business.
 
What are our information-sharing practices?
We enter into service agreements with affiliated third parties and unaffiliated third parties to provide necessary and ongoing services in connection with our investment programs. Those third parties may include investment advisory firms, securities broker-dealers, banks, insurance companies and other financial service providers. We may disclose some or all of the information that we collect, as described above, to those third parties that provide services on our behalf. In fact, those third party service providers may assist us in gathering and collecting the information from you that enables us to provide you with our advisory services. However, we contractually require those third parties to protect the confidentiality of your information.

Additionally, in connection with the ordinary administration and maintenance of your account, We must use the services of various affiliated and unaffiliated third parties, such as an account custodian that holds securities on your behalf and securities broker-dealers that execute trades you have authorized. We may disclose some of the nonpublic personal information that we collect from and about you, as described above, such as your name, address and Social Security number, to those third parties. However, we will disclose nonpublic personal information only as necessary to administer, maintain and service your account, as you request or authorize us to do, in the normal course of our advisory business.

Finally, we may share nonpublic personal information that we collect from and about you:

  • With governmental agencies, law enforcement authorities and self-regulatory organizations to the extent required or permitted by law
  • With affiliated or unaffiliated third parties, with your consent or as directed by your representative
  • With affiliated or unaffiliated third parties to the extent necessary to prevent actual or potential fraud, unauthorized transactions, claims or other liability
  • With affiliated or unaffiliated third parties for required institutional risk control or for resolving client disputes or inquiries
  • With affiliated or unaffiliated third parties otherwise as permitted by law

 
What information do we disclose about former clients and to whom do we disclose that information?
Even if you terminate your client relationship with us, we will still adhere to the privacy policies and procedures as summarized in this notice.
 
What if we change our information-sharing practices?
If, at any time in the future, it is necessary to disclose any of your personal information in a way that is inconsistent with this policy, we will give you advance notice of the proposed change so that you will have the opportunity to opt-out of that disclosure, that is, you may direct us not to make the disclosure.