PRIVACY POLICY

The Securities and Exchange Commission has adopted rules intended to protect the privacy of nonpublic information about individuals. These rules require all broker-dealers, investment companies and registered investment advisers to adopt privacy policies governing the collection and use of this nonpublic information and to inform clients of these policies. This privacy policy statement explains to you our procedures for handling and safeguarding nonpublic information that we collect from you during the normal course of business. We are committed to maintaining the confidentiality and integrity of your personal information.

Information We Collect

In the normal course of business, we collect nonpublic information about you (e.g. social security number, date of birth, income, net worth and beneficiary designations) from various sources such as:
 • Account applications, transfer forms, wire instructions, etc.
 • Copies of income tax returns, insurance policies, wills and employee benefit programs that you provide to us.
 • Information we collect from you through telephone conversations, fax, email or written correspondence.
 • Information provided to us with your authorization from independent third parties: accountants, lawyers, employers or other advisors.

Protecting Your Information

We do not provide any personal or account information about you to third parties without your prior consent or as required by law. We will only provide information to the extent that it is necessary to fulfill our advisory services to you.

Ongoing Protection

We take seriously the obligation to maintain confidentiality and protect your information. We have always maintained and continue to monitor procedures designed to protect and restrict access to your nonpublic information from third parties. The protections we employ for client data include physical, electronic and procedural safeguards.

January 2015