PRIVACY POLICY

Investment advisers are required by law to inform their clients of their policies regarding privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law. Federal law gives the customer the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information.

 

TYPES OF NONPUBLIC PERSONAL INFORMATION (NPI) WE COLLECT 

We collect nonpublic personal information about you that is either provided to us by you or obtained by us with your authorization.  This can include but is not limited to your Social Security Number, Date of Birth, Banking Information, Financial Account Numbers  and/or Balances, Sources of Income, and Credit Card Numbers or Information. When you are no longer our customer, we may continue  to share your information only as described in this notice. 

DEFINITIONS: Affiliates – companies related by common ownership or control. They can be financial and non-financial companies; Non affiliates – companies not related by common ownership or control. They can be financial and non-financial companies; Joint marketing  – a formal agreement between non-affiliated financial companies that together market financial products or services to you. 

 

PARTIES TO WHOM WE DISCLOSE INFORMATION 

All Investment Advisers may need to share personal information to run their everyday business. In the section below, we list the  reasons that we may share your personal information: 

  • For everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus; 
  • For our marketing – to offer our products and services to you; 
  • For joint marketing with other financial companies; 
  • For our affiliates’ everyday business purposes – information about your transactions and experiences and information about your creditworthiness; or 
  • For affiliates to market to you. 

If you are a new customer we may begin sharing your information on the day you sign our agreement. When you are no longer our  customer, we may continue to share your information as described in this notice. However, you can contact us at any time to limit our  sharing. 

 

PROTECTING THE CONFIDENTIALITY OF CURRENT AND FORMER CLIENT’S INFORMATION 

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law, including computer safeguards and secured files and building. We: 

  • Require new employees to review and acknowledge the firm’s compliance policy manual, which includes this privacy policy, and all employees to review and acknowledge the compliance policy manual annually. 
  • Prohibit an employee from providing client information over the telephone or in response to an e-mail message unless the employee has identified the other person as the client, a fiduciary representative of the client, an authorized agent of the client or a party that needs the information to complete a transaction for the client (such as broker-dealers, custodians or administrative service providers). 
  • Limit access to confidential information about clients to those employees who need to know such information. Maintain appropriate security measures for our computer and information systems, including the use of passwords and firewalls. - Use a shredding machine, locks and other appropriate physical security measures to safeguard client information stored in paper format. 
  • Engage a third party service provider only after we have entered into a contractual agreement that prohibits the service provider from disclosing or using confidential personal information except as necessary to carry out its assigned responsibilities and only for that purpose. 

 

FEDERAL LAW GIVES YOU THE RIGHT TO LIMIT SHARING – OPTING OUT 

Federal law allows you the right to limit the sharing of your NPI by “opting-out” of the following: sharing for non-affiliates’ everyday  business purposes – information about your creditworthiness; or sharing with affiliates or non-affiliates who use your information to  market to you. State laws and individual companies may give you additional rights to limit sharing. Please notify us immediately if you  choose to opt out of these types of sharing.