Maintaining the confidentiality of customer nonpublic personal financial information is very important to the Adviser.
“Nonpublic personal information” is nonpublic information about customers that Adviser obtains 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, the Adviser collects several types of nonpublic personal information about its 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
The Adviser does not disclose nonpublic personal information about its customers or former customers to anyone except as otherwise permitted or required by law. For example, the Adviser is permitted by law to share information about its customers with:
– Its employees and companies, as necessary to assist the Adviser in processing customer transactions and servicing accounts, such as brokerage firms and custodians.
– Customer’s authorized representatives, such as its accountant, tax preparer, lawyer, or other legal representative.
– Federal and state regulators who regulate the Adviser and its 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.
– The Adviser’s legal counsel, accountant, and compliance professionals who assist Adviser in complying with applicable laws, rules, and regulations.
The Adviser does not provide customer personally identifiable information to direct marketers or independent solicitors for any purpose.
DISCLOSURE OF INFORMATION ABOUT FORMER CUSTOMERS
If a customer decides to close its account(s), the Adviser continues to share a customer’s information as described in this notice. The Adviser maintains nonpublic personal information during the customer relationship, and for any time thereafter that the Adviser is 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
Adviser takes reasonable steps to assure the privacy of customer information. The Adviser restricts access to nonpublic personal information regarding customers to those employees who have a business or professional reason for knowing, as permitted by law. The Adviser employees are trained to follow its procedures to protect customer privacy. The Adviser maintains a secure office and computer environment to ensure that customer information is not placed at unreasonable risk. The Adviser maintains physical, electronic, and procedural safeguards that comply with federal regulations to guard customer nonpublic personal information.
The Adviser reserves the right to change its privacy policy and will inform the customer of changes or amendments as required by law.