Information We Have About You
We receive information about you that is not available publicly in order to help us serve your financial needs, offer you investment advisory services and to fulfill contractual, legal and regulatory requirements. This information is received from a variety of sources, including:
Information you provide directly to us, such as your name, address, email address, social security number, employment information, investment experience, bank account information, assets, liabilities and income.
Information about your relationship with us, such as account information including account numbers, account balances and payment history.
Information we receive with your authorization from third parties, such as financial institutions, companies, and other individuals.
Protection and Use of Information
We use the information acquired only for the purpose of providing professional investment advisory services to you. We take reasonable steps to keep confidential the information acquired. Where appropriate, information provided by us to employees, affiliates and nonaffiliated third parties who perform services for us, is subject to contractual agreement which prohibit these parties from disclosing or using the information other than for the purposes for which the information was disclosed.
Parties to Whom We Disclose Information
We do not disclose any nonpublic personal information about our clients or former clients to our affiliates or to nonaffiliated third parties except as permitted by law. Nonpublic personal information about current and former clients may be disclosed to our affiliates and to nonaffiliated third parties as permitted by law, as follows:
as necessary to effect, administer or enforce a transaction requested or authorized by the client;
as necessary to properly maintain and service such client’s account;
providing information to affiliates and nonaffiliated third parties, such as attorneys, accountants and auditors who perform services or functions for us pursuant to a contractual agreement which prohibits the affiliate or the nonaffiliated third party from disclosing or using the information other than for the purposes for which the information was disclosed;
in complying with Federal, State or local laws, rules and other applicable legal requirements;
in complying with a properly authorized civil, criminal, or regulatory investigation or subpoena or summons by Federal, state, or local authorities; or
in responding to judicial process or government regulatory authorities having jurisdiction over us for examination, compliance and other purposes as authorized by law.
Should we wish to expand the above list, clients will be notified, in writing, and given the opportunity to “opt-out” prior to the change being enacted.