- In conjunction with Federal law, Regulation S-P, adopted by the SEC pursuant to the Gramm-Leach- Bliley Act of 1999, we have the responsibility of advising you, the client, on how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
PROTECTING YOUR PRIVACY
- Your privacy is very important to us. This Privacy Notice sets forth our policies with respect to non- public personal information about our clients and prospective and former clients, and may be changed at any time, provided a notice of such change is given to you, the client.
WE PROTECT INFORMATION WE COLLECT ABOUT YOU
- We collect personal information from you upon opening an account. This information includes:
- Name and Address
- Phone Number
- Social Security Number
- Employment Data
- Driver’s License or Passport Identification
- We seek to carefully safeguard your private information and, to that end, restrict access to non-public personal and account information about you to those employees and other persons who need to know the information to enable us to provide services to you.
HOW WE SHARE INFORMATION WITH OTHERS
- We do not disclose any non-public personal information, except as permitted by law, such as to accountants, attorneys, auditors, brokers, regulators and certain service providers. In such cases, only as necessary to facilitate the acceptance and management of your investment account and our relationship with you. These entities will use this information only for the services for which we hired them, and are not permitted to use or share this information for any other purposes. We will also release information about you if you direct us to do so, if compelled to do so by law, or in connection with any government or self-regulatory organization request or investigation.
- Regulation S-P also requires a registered adviser to properly dispose of ‘consumer report information,” maintained for a business purpose, by taking reasonable measures to protect against unauthorized access to or use of the information in connection with its disposal. The Firm has adopted Policies in accordance with the law.
- Further, our clients’ primary asset custodian, Pershing Advisor Solutions (PAS), goes to great lengths to protect our clients’ privacy as well. As a member of the Financial Industry Regulatory Authority (FINRA), PAS maintains policies and procedures that address the protection of client information and records. PAS is dedicated to ensuring that their policies and procedures are up-to-date with current regulations and in line with technology changes in the industry.