We collect non-public personal information about our clients from the following sources: information we receive from our clients on applications or other forms (e.g., name, address, Social Security number, birth date, beneficiaries, assets and income, etc.) and information about our clients’ transactions with us, our affiliates, or others (e.g., trading history and account balances).
It is our policy not to disclose any non-public personal information about our clients or former clients to anyone, except as required by law. However, we may share any non-public information with the following types of third parties in order to effect securities transactions and other services on our clients’ behalf: financial service providers, such as securities broker-dealers, securities custodians and transfer agents; and other individuals or entities identified by our clients as their agent, such as accountants or attorneys.
We restrict access to non-public personal information about our clients to those employees who need to know that information to provide our services. We maintain physical, electronic, and procedural safeguards to protect our clients’ non-public personal information. We do not sell client information.
This policy will be sent annually as a reminder to each of our clients and is provided at the onset of our relationship with each client.