Privacy Policy

As general policy, the Company will not disclose personal financial information about any client to non-affiliated third parties except as necessary to establish and manage the client’s account(s) or as required by law. In these situations, personal financial information about a client may be provided to the broker/dealer or other custodian maintaining these accounts.

In addition, the Company will restrict access to clients’ non-personal financial information to those employees who need to know such information in order to provide products or services to clients. The Company will maintain physical, electronic, and procedural safeguards that comply with federal standards to guard each client’s personal financial information. Such safeguards include restricting the use of any information provided by the client to each client’s personal account manager, the manager’s supervisor and the Company’s CCO or such other persons as the CCO deems as needing to know the information. Hard copy of client personal financial information will be maintained in the Company’s central files, and will be secured (locked) after normal business hours. Electronic access to client personal financial information will be restricted to the client’s account manager handling the account through the Company’s local area network (LAN). Electronic LAN access will also be available to the manager’s supervisor and the Company’s CCO.