Privacy Policy Standards

Protecting information with disciplined governance.

Privacy Protections for Your Financial Information

Investment advisers are required by law to inform clients of their policies regarding the 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 customers the right to limit some, but not all, sharing of personal information. It also requires us to inform 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 by you or obtained with your authorization. This may include, but is not limited to, your Social Security number, date of birth, banking information, financial account numbers and/or balances, sources of income, credit card numbers, and other relevant information.

When you are no longer our customer, we may continue to share your information only as described in this notice.

Parties to Whom We Disclose Information

All investment advisers may need to share personal information to conduct their everyday business. Below are the typical
reasons we may share your personal information:

  • For everyday business purposes — such as processing transactions, maintaining your account(s), responding to court orders and legal investigations, or reporting to credit bureaus;
  • For marketing purposes — 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; or
  • For non-affiliates to market to you.

Clients may opt out of sharing information for joint marketing with other financial companies, with our affiliates, and with non-affiliates. 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 may contact us at any time to limit our sharing.

Protecting the Confidentiality of Current and Former Client Information

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

Federal Law Gives You the Right to Limit Sharing — Opting Out

Federal law allows you to limit the sharing of your NPI by opting out of the following:

  • Sharing for affiliates’ everyday business purposes — information about your creditworthiness;
  • Sharing with affiliates who use your information to market to you; or
  • Sharing with non-affiliates to market to you.

State laws and individual companies may provide additional rights to limit sharing. Please notify us promptly at our address or telephone number if you choose to opt out of these types of sharing.

Definitions:

  • Affiliates — Companies related by common ownership or control. They may be financial or nonfinancial companies.
  • Non-affiliates — Companies not related by common ownership or control. They may be financial or nonfinancial companies.
  • Joint marketing — A formal agreement between non-affiliated financial companies that jointly market financial products or services to you.

Please call us if you have any questions. Your privacy, our professional ethics, and our ability to provide you with high-quality financial services are very important to us.