Privacy Policy
Except as otherwise agreed in writing or as required by law, the Firm will keep confidential all information concerning Client's identity, financial affairs and/or investments. The Firm does not sell or rent Client information. The Firm will use certain confidential Client information to conduct business with Client; to develop or enhance its products and services; to understand the financial needs of Client so that the Firm can provide Client with quality products and superior service; and to protect and administer Client's records, accounts and funds. The Firm does not disclose nonpublic personal information about Client to nonaffiliated third parties or to affiliated entities, except as permitted or required by law. For example, the Firm may share nonpublic personal information in the following situations:
- To service providers in connection with the administration and servicing of the Firm, which may include attorneys, accountants, auditors and other professionals. The Firm may also share information in connection with the servicing or processing of client transactions;
- To affiliated companies in order to provide you with ongoing personal advice and assistance with respect to the products and services you have purchased through the Firm and to introduce you to other products and services that may be of value to you;
- To respond to a subpoena or court order, judicial process or regulatory authorities;
- To protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities; and
- Upon consent of an investor to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the investor.
The Firm's policy is to require that all employees, financial professionals and companies providing services on its behalf keep client information confidential.
The Firm maintains safeguards that comply with federal standards to protect investor information. The Firm restricts access to the personal and account information of investors to those employees who need to know that information in the course of their job responsibilities. Third parties with whom the Firm shares investor information must agree to follow appropriate standards of security and confidentiality. The Firm's privacy policy applies to both current and former investors. The Firm may disclose nonpublic personal information about a former investor to the same extent as for a current investor.
The Firm may make changes to its privacy policy in the future. The Firm will not make any change affecting you without first sending you a revised privacy policy describing the change.