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The following information will help clients understand our privacy
policy and how we will handle and maintain confidential personal
information as we fulfill our obligations to protect their privacy.
“Personal Information” refers to the nonpublic financial
and personal information obtained by us in connection with providing
clients a financial product or service.
The categories of persons to whom personal information
may be disclosed
We will not disclose personal information about current or former
clients to non-affiliated third parties except as permitted or required
by law. We do not sell any personal information about clients to
any third party. In the normal course of business, personal information
may be shared with persons or entities involved in servicing and
administering products and services on our behalf, including: a
client’s custodians, attorneys, accountants or other service
providers and affiliates assisting the client.
The categories of personal information that the firm collects
We collect personal information to help us serve clients’
financial needs, offer new products or services, provide customer
service and fulfill legal and regulatory requirements. The type
of information that we collect varies according to the products
or services involved and may include:
- Information we receive from clients on applications and related
forms (such as name, address, social security number, assets and
income); and,
- Information about clients’ transactions and relationships
with our affiliates, other service providers, or us (such as products
or services purchased, account balances and payment history).
Policy for protecting the confidentiality and security
of personal information
We have procedures in place that limit access to personal information
to those employees and service providers who need to know such information
in order to perform business services on our behalf. We educate
our employees on the importance of protecting the privacy and security
of confidential personal information. We also maintain physical,
electronic and procedural safeguards that comply with federal and
state regulations to guard clients’ personal information.
Policy and practices with respect to disclosing personal
information relating to former customers
If a client decides to close his, her or their account(s) with
us, or become an inactive client, we will adhere to the privacy
policies and practices described in this Policy Statement as they
relate to this former client.
We will update our policy and procedures where necessary to ensure
that each client’s privacy is maintained and that we conduct
our business in a way to fulfill our commitment to all of our clients.
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