Your Privacy is Protected.

An important part of our commitment to you is our respect for your right to privacy. Protecting all the information we are either required to gather or which accumulates in the course of doing business with you is a cornerstone of our relationship with you. While the range of products and services we offer continues to expand, and the technology we use continues to change, our commitment to maintaining standards and procedures with respect to security remains constant.

Privacy of Client Financial Information (Regulation S-P).

Regulation S-P requires us to adopt policies and procedures reasonably designed to: (a) ensure the confidentiality of Client records and information; (b) protect against any anticipated threats or hazards to the security of Client records and information; and (c) protect against unauthorized access or use of Client records or information that could result in “substantial harm or inconvenience” to any Client. The privacy provisions of Regulation S-P apply to information that is “nonpublic personal information.” For the purpose of this policy, Client means any US person or entity for which we serve as Investment Advisor, render investment advice or make investment decisions.

Regulation S-P.

Nonpublic personal information under Regulation S-P includes “personally identifiable financial information” and any list, description, or grouping that is derived using any personally identifiable financial information that is not publicly available information.

Personally identifiable financial information includes three categories of information:

  1. Information Supplied by Client: Any information that is provided by a Client or prospective Client to us in order to obtain a financial product or service. This would include information or material given to us when entering into an investment advisory agreement.
  2. Information Resulting from Transaction: Any information that results from a transaction with the Client or any services performed for the Client. This category would include information about account balances, securities positions, or financial products purchased or sold through a broker-dealer.
  3. Information Obtained in Providing Products or Services: Any information obtained by us from a consumer report or other outside source that is used by us to verify information that a Client or prospective Client has given on an application for advisory services.

Collection of Information.

The primary reason that we collect and maintain information is to more effectively administer our customer relationship with you. It allows us to identify, improve and develop products and services that we believe could be of benefit. It also permits us to provide efficient, accurate and responsive service, to help protect you from unauthorized use of your information and to comply with regulators’ and other legal requirements. These include those related to institutional risk control and the resolution of disputes or inquiries.

Various sources are used to collect information about you, including: (i) information you provide to us at the time you establish a relationship; (ii) information provided in applications, forms or instruction letters completed by you; (iii) information about your transactions with us or our affiliated companies; and/or (iv) information we receive through an outside source, such as a bank or credit bureau. In order to maintain the integrity of client information, we have procedures in place to update such information, as well as to delete it when appropriate. We encourage you to communicate such changes whenever necessary.

Disclosure of Information.

We do not disclose any nonpublic, personal information (such as your name, address or tax identification number) about our clients or former clients to anyone, except as permitted or required by law or otherwise as directed in writing by the Client.

The law permits us to share client information with companies that are affiliated with us which provide financial, credit, insurance, trust, legal, accounting and administrative services to us or our clients. This allows us to enhance our relationship with you by providing a broader range of products to better meet your needs and to protect the assets you may hold with us by preserving the safety and soundness of our firm.

Accordingly, nonpublic personal information about a Client may be provided to the broker-dealer or other custodian for maintaining or servicing the Client’s account or processing or servicing a financial product or service that the Client requests or authorizes. In addition, the Company will limit access to Clients’ nonpublic personal information to only those employees who need to know such information to provide products or services to Clients, and will maintain physical, electronic and procedural safeguards to prevent such information against unauthorized access and disclosure.

It may be necessary, under anti-money laundering or other laws, to disclose information about you in order to accept your subscription. Information about you may also be released if you so direct, or if we, or an affiliate, are compelled to do so by law, or in connection with any government or self-regulatory organization request or investigation.

Finally, we are also permitted to disclose nonpublic, personal information to unaffiliated outside parties who assist us with processing, marketing or servicing a financial product, transaction or service requested by you, administering benefits or claims relating to such a transaction, product or service, and/or providing confirmations, statements, valuations or other records or information produced on our behalf.


We are committed to upholding this Privacy Policy. We will notify you on an annual basis of our policies and practices in this regard and at any time that there is a material change that would require your consent.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit the CCPA Privacy Notice.