Maintaining the confidentiality of customer nonpublic personal financial information is very important to us. 

“Nonpublic personal information” is nonpublic information about customers that we obtain in connection with providing a financial product or service to a customer for personal, family, or household purposes. It does not include information available from government records, widely distributed media or government mandated disclosures. 

INFORMATION THE ADVISER COLLECTS FROM CUSTOMERS

To provide customers with superior service, we collect several types of nonpublic personal information about our customers, including: 

  • Information on account applications or custodian forms such as name, address, social security number, and assets. 
  • Information regarding customer transactions, including such matters as the customer account balance, investment portfolio, investment cost, investment gain or loss. 

THIRD PARTIES WITH WHOM THE ADVISER MAY SHARE INFORMATION

We do not disclose nonpublic personal information about our customers or former customers to anyone except as otherwise permitted or required by law. For example, we are permitted by law to share information about our customers with: 

  • Its employees and companies, as necessary to assist us in processing customer transactions and servicing accounts, such as brokerage firms and custodians. 
  • Customer’s authorized representatives, such as their accountant, tax preparer, lawyer, or other legal representative. 
  • Federal and state regulators who regulate us and our representatives or other government entities or third parties in response to subpoenas or other legal process as required by law or to comply with regulatory inquiries. 
  • Our legal counsel, accountant, and compliance professionals who assist us in complying with applicable laws, rules, and regulations. 

We do not provide customer personally identifiable information to direct marketers or independent solicitors for any purpose. 

NOTICE REGARDING THE USE OF ARTIFICIAL INTELLIGENCE (“AI”) 

Our firm utilizes AI technology in certain areas of our business to improve efficiency such as to generate summaries of client meetings, draft follow-up emails and create agendas for future meetings, assist in drafting newsletters, blogs, and educational materials that are shared with clients and/or published on our website. We strictly prohibit the use of predictive AI to make investment-related decisions or employment-related decisions. All investment recommendations and employment determinations are made exclusively by qualified professionals of the firm. We have adopted policies and procedures designed to protect confidential and nonpublic information when using AI tools. This includes masking sensitive information to mitigate privacy and data security risks.

We require a client’s express consent prior to recording any client meeting. AI-generated meeting summaries and client correspondence are reviewed for accuracy. 

DISCLOSURE OF INFORMATION ABOUT FORMER CUSTOMERS

If a customer decides to close their account(s), we continue to share a customer’s information as described in this notice. We maintain nonpublic personal information during the customer relationship, and for any time thereafter that we are required to maintain the records for federal and state securities laws. After this required period of record retention, all of the customer’s information will normally be destroyed. 

ADVISER’S SECURITY POLICIES AND PRACTICES

We take reasonable steps to assure the privacy of customer information. We restrict access to nonpublic personal information regarding customers to those employees who have a business or professional reason for knowing, as permitted by law. Our employees are trained to follow our procedures to protect customer privacy. We maintain a secure office and computer environment to ensure that customer information is not placed at unreasonable risk. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard customer nonpublic personal information. 

We reserve the right to change our privacy policy and will inform the customer of changes or amendments as required by law.