PRIVACY POLICY

We consider customer privacy to be a fundamental aspect of our relationship with clients. We are committed to maintaining the confidentiality, integrity, and security of our current, prospective and former clients’ personal/corporate information. We have developed policies designed to protect this confidentiality, while allowing client needs to be served.

In the course of providing you with our services, we may obtain non-public personal/corporate information about you. This information may come from sources such as account applications and other forms, from other written, electronic or verbal correspondence, from your transactions, from your brokerage, consultant, and/or from information captured on our internet web sites.

We do not disclose any personal/corporate or account information provided by you or gathered by us to non-affiliated third parties, except as required or permitted by law. As is common in the industry, non-affiliated companies may from time to time be used to provide certain services, such as preparing and mailing prospectuses, reports, account statements and other information. These companies may have access to your personal/corporate and account information, but are permitted to use the information solely to provide the specific service or as otherwise permitted by law.

We do reserve the right to disclose or report personal/corporate information to non-affiliated third parties in limited circumstances where we believe in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities, or to protect our rights or property. In addition, we may disclose information about you or your accounts to a non-affiliated third party at your request or if you consent in writing to the disclosure.

We take seriously the obligation to safeguard your non-public personal/corporate information. We have implemented procedures designed to restrict access to your non-public personal/corporate information to our personnel who need to know that information to provide products or services to you. To guard your non-public personal/corporate information, physical, electronic, and procedural safeguards are in place.