Investment Advisers are required by law to inform their clients of their policies regarding privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law. Federal law gives customers the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information.

Types of Nonpublic Personal Information (NPI) We Collect

We collect nonpublic personal information about you that is either provided to us by you or obtained by us with your authorization. This can include but is not limited to your Social Security Number, Date of Birth, Banking Information and Financial Account Numbers and/or Balances, Sources of Income, Credit Card Numbers or other Information. When you are no longer our customer, we may continue to share your information only as described in this notice.

Parties to Whom We Disclose Information

All Investment Advisers may need to share personal information to run their everyday business. In the section below, we list the typical reasons that we may share your personal information:

• For everyday business purposes – such as to process your transactions, maintain your account(s), or respond to court orders and legal investigations, or report to credit bureaus;
• For our marketing – to offer our products and services to you;

Clients may opt out of sharing information for joint marketing to other financial companies, to our affiliates and to non-affiliates. If you are a new customer we may begin sharing your information on the day you sign our agreement. When you are no longer our customer, we may continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

Protecting the Confidentiality of Current and Former Client’s Information

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law, including computer safeguards and secured files and building.

Federal Law Gives You the Right To Limit Sharing – Opting Out

Federal law allows you the right to limit the sharing of your NPI by “opting-out” of the following: sharing for affiliates’ everyday business purposes – information about your creditworthiness; sharing with affiliates who use your information to market to you; or sharing with non-affiliates to market to you. State laws and individual companies may give you additional rights to limit sharing. Please notify us immediately at our address or telephone number if you choose to opt out of these types of sharing.

Online Privacy

When you interact with us through our website, we manage nonpublic personal information in accordance with the privacy notice above.  In addition, when you visit our website, we may collect technical and navigational information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on our website.  We use this information for a variety of purposes, such as maintaining the security of your online session, facilitating site navigation, improving website design and functionality, and personalizing your experience on our website.

Cookies and Similar Technologies

We may use cookies and similar technologies to support the operation of our website.  Cookies are small amounts of data that a website sends to a web browser on a visitor’s computer.  Cookies help us to collect information about visitors to our websites, including date and time of visits, pages viewed, amount of time spent on our sites, or general information about the device used to access the site.  Cookies may also be used to provide access to enhanced features of our website, such as watching videos.  You can refuse or delete cookies.  Most browsers and mobile devices offer their own settings to manage cookies.  Please see www.aboutcookies.org for more information.  If you refuse or delete a cookie, you may experience some inconvenience in your use of our website.  We may also embed sharing tools or advertising features from other (third party) sites, specifically Google Analytics.  Information on these third-party sites, and whether and how you may opt-out of receiving cookies from them, can be found at www.google.com/intl/en/analytics/learn/privacy.html.  You may opt-out of Google Analytics at https://tools.google.com/dlpage/gaoptout.

DEFINITIONS: Affiliates – companies related by common ownership or control.  They can be financial and nonfinancial companies; Non-affiliates – companies not related by common ownership or control.  They can be financial and nonfinancial companies; Joint marketing – a formal agreement between non-affiliated financial companies that together market financial products or services to you.