Privacy Policy

Investment advisers are required by law to inform their clients of their policies regarding the privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law. Federal law gives you the right to limit some, but not all, sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information.

Types of Nonpublic Personal Information (NPI) We Collect

We collect nonpublic personal information about you that is either provided to us by you or obtained by us with your authorization. This can include, but is not limited to, your Social Security number, date of birth, banking information, financial account numbers and/or balances, sources of income, and credit-card information. When you are no longer our customer, we may continue to share your information only as described in this notice.

Parties to Whom We Disclose Information

All investment advisers may need to share personal information to run their everyday business. We may share your personal information:

• For everyday business purposes such as processing transactions, maintaining your account(s), responding to court orders and legal investigations, or reporting to credit bureaus.
• For our marketing — to offer our products and services to you.
• For joint marketing with other financial companies.
• For our affiliates' everyday business purposes, including information about your transactions and experiences and information about your creditworthiness.
• For non-affiliates to market to you.

If you are a new customer, we may begin sharing your information on the day you sign our agreement. When you are no longer our customer, we may continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

Protecting Confidentiality of Current and Former Clients' Information

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law, including computer safeguards and secured files and buildings.

Federal Law Gives You the Right to Limit Sharing (Opting Out)

Federal law allows you to limit the sharing of your NPI by opting out of:

• Sharing for affiliates' everyday business purposes — information about your creditworthiness.
• Sharing with affiliates or non-affiliates who use your information to market to you.

State laws and individual companies may give you additional rights to limit sharing. Please notify us immediately if you choose to opt out of these types of sharing.

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