PRIVACY POLICY

PRIVACY POLICY

Under Securities and Exchange Commission (SEC) regulations, we are required to provide a notice to each of our individual clients explaining our policies and practices relating to disclosing personal information about you to unrelated third parties.  For your information, this requirement is based upon a SEC regulation, called Regulation S-P, which applies to every investment adviser that is registered with the SEC.  As a general matter, it has always been our policy not to disclose information about you to any other party, and to maintain strict security over personal information about you in our possession.

Information We Collect

We collect nonpublic personal information about you from applications or other account forms you complete, from your transactions with us, and conversations over the telephone or email.

Information We Disclose

We do not disclose information about you, or our former clients, to our service providers or other third parties except on a limited basis permitted by law.  For example, we may disclose nonpublic information about you to third parties to assist us in servicing your account and to send transaction confirmations, quarterly and annual reports, and tax forms to you.

Our Security Procedures

To ensure the highest level of confidentiality and security, we maintain physical, electronic and procedural safeguards that comply with federal standards to guard your personal information.

What should I do with this notice?

As we indicated above, all registered investment advisers are subject to Regulation S-P and have to make a similar notice to their customers.  Also, we are required to send this notice to you on a yearly basis, and we suggest that you keep this notice with your files.  Do not hesitate to contact us if you have any questions regarding this notice, or if you have any other questions.