Understanding each client’s investment objectives is the founda¬tion for the services we provide. The personal information clients provide, allows us to help meet their financial needs. We are commit¬ted to maintaining confidential¬ity, integrity, and security. We understand your desire for discretion in handling your financial matters, and we appreci¬ate the trust you have placed in us to keep your information confidential.

This Privacy Policy explains what personal information we collect, why we collect it, how we protect it, and in what cir¬cumstances we may share it.

How and why we collect personal information

We collect and maintain information about clients in order to evaluate their financial needs and provide financial services to meet those needs. Most of the information we collect comes directly from you – from applications, agreements, or forms that you complete to receive our services. You may also provide us information when com¬muni-cating with us in writing, electronically, or by phone. We collect information from and about you to:

  • identify you as our client;
  • establish and manage your accounts;
  • complete your transactions;
  • understand your needs through market research;
  • inform you of products and services that may meet your needs; and
  • compliance with legal and regulatory requirements.

Protecting your privacy

We consider protecting your personal information essential to building client trust and maintaining sound busi¬ness practices. That is why we do not sell information about current or former clients to any third parties. We also do not disclose any nonpublic information about current or former clients, except:

  • as requested or authorized by our clients;
  • as necessary to process a transaction or service an account;
  • as requested by securities or other regulatory authorities;
  • pursuant to subpoena; or
  • as otherwise required by law.
We may disclose information about you or your account to:

affiliates and nonaffiliated companies that perform adminis¬trative or marketing services on our behalf to help us service your account(s), such as printing and mailing companies, and

Our contracts with third parties restrict their use of client infor¬mation and require them to implement safeguards to maintain its confidentiality. We restrict access to your personal information to those em¬ployees who need to know that information to provide invest¬ment products or services to you. Employees with access to your personal information must maintain and protect its confi¬dentiality and follow established safeguarding procedures. We strive to maintain the highest standards of confidentiality and to always respect clients’ privacy. We are committed to protecting your information on our web¬site with the same care we use for all our transactions.