Privacy Notice
Your privacy is important to us. While information is the
foundation of our business, our most important asset is your trust.
Gramm-Leach-Bliley Act
The Securities and Exchange Commission (SEC) Rules under this act
require us:
- To provide notice to you describing our privacy
policies and practices,
- To not disclosing any nonpublic personal
information to non-affiliated third parties unless you have a
reasonable opportunity (to "opt-out), and
- To adopt procedures to safeguard your privacy
This notice applies to individuals, not businesses or corporations,
and to former clients. It will be distributed to you when you open
an account, and an annual notice will be distributed to you as a part of
our annual portfolio appraisal.
- Our Policies and Practices
- We safeguard, according to strict standards of security and
confidentiality, any information you share with us.
- We limit the collection and use of your information to the
minimum we require to deliver superior service to you to
administer our business, which includes advising you about our
products, services and other opportunities.
- We permit only authorized employees, who are trained in the
proper handling of customer information, to have access to that
information. Employees who violate our privacy standards
will be subject to our normal disciplinary process.
- We will not reveal customer information to any external
organization unless we have previously informed you in
disclosures or agreements, have been authorized by you, or are
required to make such disclosure by law or by our regulators.
- Nonpublic personal information we may disclose subject to your option to "Opt Out"
- Information we receive from you on applications or other
forms, such as your name, address, and telephone number,
- Information about your transactions with us, our affiliates,
or non-affiliated third parties, such as your account balances,
payment history, and account activity,
- Information we receive about you from other sources, such as
your employer and other third parties.
- We do not disclose any nonpublic personal
information listed in "B" about you or our former clients, except to
non-affiliate third-party companies who provide us services or as
permitted by law or by our regulators.
- Custodial brokers
- Computer service companies
- Portfolio systems software companies
- General administrative service companies
We require them to agree to secure the privacy of your nonpublic
information we share with them which is essential to our business.
- If we intend to disclose non-public personal
information such as that set forth in "B" to persons other than
those set forth in "C", we will so notify you in advance and give
you an opportunity to "opt out" of such disclosure.