We are committed to safeguarding the confidential information of our clients. We hold all personal information provided to our firm in the strictest confidence. We may also have relationships with other nonaffiliated investment advisor firms such as Schwab Institutional and Fidelity Investments. Except as required or permitted by law, we do not share confidential information about you with nonaffiliated third parties. In the unlikely event there were to be a change in this fundamental policy that would permit additional disclosure of your confidential information, we will provide written notice to you, and you will be given an opportunity to direct us as to whether such disclosure is permissible.
REQUIREMENTS OF FEDERAL LAW. In June 2000, the Securities and Exchange Commission (SEC) released Regulation S-P, a rule intended to protect the privacy of nonpublic financial information about Individuals. Regulation S-P requires certain financial institutions, including broker-dealers and investment advisers, to protect the privacy of Customer Information. To the extent of financial institution disclosed Customer Information to nonaffiliated third parties other than as permitted or required by law, customers must be given the opportunity and means to opt out (or Prevent) such disclosure. Please note that we do not disclose Customer Information to nonaffiliated third parties except as permitted or required by law (e.g., disclosures to service your account or to respond to subpoenas). No confidential information, whatever the service, regarding customer or client may be disclosed except as follows: (1) to other employees in connection with the advisor's business (2) to an affiliate, but the affiliate may disclose the information only to the same extent as the advisor (3) to non-affiliated third parties with whom the advisor has a confidential agreement to jointly offer, endorse, or sponsor a financial product or services, and to service or maintain customer accounts, including effectuating transactions.
AN IMPORTANT NOTICE CONCERNING OUR CUSTOMERS’ PRIVACY .
CUSTOMER INFORMATION WE COLLECT. We collect and develop personal information about you, and some of that information is nonpublic and personal information ("Customer Information"). The essential purpose for collecting Customer Information is to provide and service the financial products and services you obtain from our firm. The categories of Customer Information collected by us depend upon the scope of the engagement with us and are generally described below. As an investment adviser, we collect and develop Customer Information about you in order to provide investment advisory services. Customer Information we collect includes:
- Information we receive from you on financial inventories through consultation with our Associates. This Customer Information may include personal and household information such as income, spending habits, investment objectives, financial goals, statements of accounts, and other records concerning your financial condition and assets, together with information concerning employee benefits and retirement plan interests, wills, trust, mortgages and tax returns.
- Information developed as part of financial plans, analyses or investment advisory services.
- Information concerning investment advisory account transactions.
- Information about your financial products and services transactions with us.
DATA SECURITY. We restrict access to Customer Information to those Associates and employees who need the information to perform their job responsibilities within our firm. We maintain agreements, as well as physical, electronic and procedural securities measures that comply with federal regulations to safeguard Customer Information about you.