EFFECTIVE DATE: JANUARY 1, 2023
Information We Collect: We collect nonpublic information about you ("Customer Information"). The essential purpose for collecting Customer Information is to allow us to provide advisory services to you. Customer Information we collect may include the following:
- Information that you provide on applications or other forms. This Customer Information may include personal and household information such as income, spending habits, investment objectives, financial goals, statements of account, and other records concerning your financial condition and assets, together with information concerning employee benefits and retirement plan interests, wills, trusts, mortgages, and tax returns.
- Identifying information such as your name, age, address, social security number, etc.
- Information about your transactions with us or others (e.g., broker-dealers, clearing firms, or other chosen investment sponsors).
- We receive information from consumer reporting agencies (e.g., credit bureaus) and other materials we may use to provide an appropriate recommendation or to fill a service request.
Security of Your Information: We restrict access to your nonpublic personal information to those employees who need to know that information to service your account. We maintain physical, electronic, and procedural safeguards that comply with applicable federal or state standards to protect your nonpublic personal information.
Information We Disclose: We do not disclose the nonpublic personal information we collect about our customers to anyone except (i) in furtherance of our business relationship with them and then only to those persons necessary to effect the transactions and provide the authorized services (such as broker-dealers, custodians, independent managers, etc.); (ii) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, consultants, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided by law.
We are permitted by law to disclose nonpublic personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf or for joint marketing programs). These third parties are prohibited from using or sharing the information for any other purpose.
Former Clients: If you decide to close your account(s) or become an inactive customer, we will adhere to our privacy policies, which may be amended occasionally.
Questions: If you have questions about this privacy notice or the privacy of your customer information, call our main number (800) 622‐1045 and ask to speak to the Chief Compliance Officer.