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Privacy Policy
POLICY
It is the Firm's policy to protect and safeguard the privacy and security of the personal information the Firm obtains about its "customers" (as that term is defined in Regulation S-P and shall, within this policy and procedures regarding privacy of client information, hereafter be referred to as its "clients").
BACKGROUND
Protecting the privacy and security of the personal information that an adviser obtains about its clients is an important responsibility. Clients expect advisers to service them in an accurate and efficient manner. To do so, advisers must collect and maintain certain personal information about its clients. The Firm seeks to educate its clients about what information it collects and how it uses and safeguards that information.
RESPONSIBILITY
The Chief Operations Officer is responsible for protecting and safeguarding the privacy and security of client information.
PROCEDURES
Information the Firm Collects
The Firm collects certain nonpublic personal identifying information about its clients (such as their name, address, social security number, etc.) from information that the clients provide on applications or other forms as well as communications (electronic, telephone, written or in person) with them or their authorized representatives (such as their attorney, accountant, etc.). The Firm also collects information about their brokerage accounts and transactions (such as purchases, sales, account balances, inquiries, etc.).
Information the Firm Discloses
The Firm does not disclose the nonpublic personal information it collects about its clients to anyone except: (i) in furtherance of its business relationship with them and then only to those persons necessary to effect the transactions and provide the services that they authorize (such as broker-dealers, custodians, independent managers etc.); (ii) to persons assessing its compliance with industry standards (e.g., professional licensing authorities, etc.); (iii) its attorneys, accountants, consultants, and auditors; or (iv) as otherwise provided by law.
The Firm is permitted by law to disclose the nonpublic personal information about its clients to other third parties in certain circumstances such as third parties that perform administrative or marketing services on its behalf or for joint marketing programs. These third parties are prohibited to use or share the information for any other purpose. If clients decide at some point to either terminate the Firm's services or become inactive, the Firm will continue to adhere to its privacy policy, as may be amended from time-to-time.
Security of Client Information
The Firm restricts access to its clients' nonpublic personal information to those persons who need to know that information to service the client's account. It maintains physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect their nonpublic personal information.
Changes to this Privacy Policy
The Firm's policy about obtaining and disclosing information may change from time-to-time. In all such instances, the Firm will provide its clients with notice of any material change to this policy before implement the change.
