Privacy Policy

Overview
It is the policy of the company, with respect to the use, safeguarding and disclosure of nonpublic personal information collected by the company, to comply with applicable federal and state laws and regulations concerning privacy of consumer financial information. The company respects the financial privacy of its clients and consumers (clients and consumers hereafter collectively called “clients”) and will maintain standards to ensure that each client’s nonpublic personal information is private and secure at all times.

Strict Security Measures
The company has security standards and procedures to prevent unauthorized access to client information. The company maintains physical, electronic and procedural safeguards to guard client information.

Employee Education
The company educates its employees about the importance of confidentiality and client privacy and takes appropriate disciplinary measures to enforce employee responsibilities regarding client information.

Collection of Information
The company collects information about clients to: identify them accurately; protect and administer their records, accounts and funds; help design or improve its products and services; understand their financial needs; offer quality products and services; and in order to comply with certain laws and regulations.

Sources of Information
The types and categories of information that the company collects and maintains include:
• Information received from clients to open an account or provide investment advice or other services (such as the client’s home address, social security number, telephone number, financial information and investment objectives);
• Information for servicing the client account or from company transactions with the client; and
• Information related to client transactions with nonaffiliated third parties.

The Selective Sharing of Information
The company may share information with any affiliated party, as well as with unaffiliated third parties external to the company only in the limited circumstances that this Policy describes. In order to provide investment advisory and other services to its clients, the company will disclose its clients’ personal information in very limited instances, which will include disclosures to nonaffiliated companies as permitted by law, including those who help the company service client accounts (such as providing account information to brokers and custodians), and other limited disclosures as permitted by law (such as required reports to government entities). The company will not share clients’ nonpublic personal information with third parties for marketing purposes. The company will not sell client information.

Former Clients
The company will continue to adhere to the information policies and practices described in this Policy after a client ends his or her relationship with the company.