Privacy Policy

The Regulatory Framework

 

Under Regulation S-P, financial institutions are required to secure customer records and establish strict physical and procedural safeguards. Strict duty of confidentiality rules mandate that advisors and consulting firms only share material nonpublic information with employees or agents who have a strict "need to know"

​

Privacy Policies

​

We have policies to maintain the confidentiality and security of nonpublic personal information. The following is designed to help you understand what information we collect and how we use that information to provide financial and investment advisory services.

​

Categories of Information We May Collect

​

In the normal course of business, we may collect the following types of information:

Information provided in the subscription documents and other forms (including name, address, social security number, date of birth, income, and other financial-related information); and data about transactions with us (such as the types of investments made and account status).

​

How We Use Information That We Collect

​

Any and all nonpublic personal information that we receive with respect to our clients who are natural persons is not shared with unaffiliated third parties which are not service providers to us without prior notice to, and consent of, such clients, unless otherwise required by law. In the normal course of business, we may disclose the kinds of nonpublic personal information listed above to unaffiliated third-party service providers involved in servicing and administering products and services on our behalf. Our service providers include, but are not limited to, our administrator, our auditors, insurance agent, estate attorney, and our legal advisor. Additionally, we may disclose such nonpublic personal information as required by law (such as to respond to a subpoena) or to satisfy a request from a regulator and/or to prevent fraud. Without limiting the foregoing, we may disclose nonpublic personal information about our clients to governmental entities and others in connection with meeting our obligations to prevent money laundering including, without limitation, the disclosure that may be required by the Uniting and Strengthening America Act by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001 and the regulations promulgated thereunder. In addition, if we choose to dispose of our clients’ nonpublic personal information that we are not legally bound to maintain, then we will do so in a manner that reasonably protects such information from unauthorized access. The same privacy policy also applies to former clients who are natural persons.

 

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Confidentiality and Security

We restrict access to nonpublic personal information about our clients to those employees and agents who need to know that information to provide products and services to our clients. We maintain physical, electronic and procedural safeguards to protect our clients’ nonpublic personal information. We respect and value our clients’ trust with their private financial information, and we work diligently to maintain that trust.