Firm Privacy Policy

The firm will not disclose information outside of the below exceptions.  As part of firm policy, confidential personal information will be restricted only to APs who need to know the information to provide advisory services.

Physical, electronic, and procedural safeguards will be maintained to comply with regulatory standards to guard client non-public personal information (NPI).  The firm will provide a reasonable means to prevent NPI from being disclosed to non-affiliated parties. The firm will attempt to enter into a written arrangements that require service providers to maintain confidentiality of client NPI.

Clients may opt out of the release of their information, and the firm will not require the client to write a letter to opt out.  There are no opt out rights for the release of NPI the firm makes to service providers, however, the firm will disclose to its client via its privacy policy statement the nature of any information to be shared. Opt out rights typically do not apply to disclosure of NPI in the following circumstances:

• Client has consented to and not revoked the disclosure.
• Resolving client disputes or inquiries.
• Personnel holding legal or beneficial interest relating to the client.
• Persons acting in a fiduciary capacity on behalf of the client.
• Providing information to regulatory agencies assessing the firm’s compliance with regulations.
• When required to firm legal counsel, consultants, accountants, auditors, etc., in performing their services.