Protecting our clients’ privacy is important to us. The purpose of this notice is to explain the information we collect about our clients and how we use it.

Information We Collect

In the ordinary course of business, we collect, retain and use information about our clients’ financial situation in order to service them with high professional standards. This information is collected from several sources, and may include information we receive from our clients whether in writing, in person, by telephone, electronically or on applications or other forms, and may include information about their transactions with us, our affiliates, and others which may consist of information about account balances and counterparties to transactions; information we might receive from credit reporting companies such as credit reports; and information collected from the Internet.

Information We Disclose 


We do not sell any information about our clients. Only upon our client’s specific request will information such as name, income, and assets be shared with our affiliates. From time to time and when we deem it necessary to facilitate the handling of our relationship with our clients, we will share appropriate information with third parties and partner companies as permitted by law. We only share information that is required for third parties to perform their job. For example, we may disclose information to third parties such as data processing providers for statement mailing and check printing, and securities broker dealers when using them to execute orders; to government entities in response to obligatory provision of information, and as otherwise requested by our clients.

Security of Information

We maintain physical, electronic, and procedural safeguards to guard our clients’ personal information. We have strict internal policies against unauthorized use or disclosure of client information. Our clients’ information is accessible only to employees who need it to conduct our clients’ financial affairs or provide services to them. Our employees, and our account management practices, are governed by extensive regulatory procedures, and by internal procedures. Our staff members are reminded on a regular basis of their obligations with regard to the confidentiality of client information through employee training and by operating procedures.