This notice is for your information and no response is required.
In the conduct of our business with you, we often need to collect what is known as "nonpublic personal information." This information may include such things as your name and address, social security number, assets, income, accounts with other institutions, etc.
Under Securities and Exchange Commission regulations, we are required to provide a notice to each of our individual customers explaining our policies and practices relating to our disclosure of that information to our affiliates and to unrelated third parties.
For your information, this requirement is based upon a new SEC regulation, called Regulation S-P, that applies to every investment adviser registered with the SEC. As a general matter, it is (and has always been) our policy not to disclose information about you to any other party, except as necessary to provide you with the services you have requested and authorized, and to maintain strict security over personal information about you which we have in our possession. We describe these policies in further detail below.
WHAT ARE THE CATEGORIES OF PERSONAL INFORMATION ABOUT YOU THAT WE COLLECT?
We collect personal information from you based upon the information you have provided to us in your custodian's account forms. We also collect information when we effect transactions for you as well as from on-going conversations and correspondence with you that allow us to provide asset management services to you based upon your needs and goals.
WHAT, IF ANY, PERSONAL INFORMATION DO WE DISCLOSE TO OTHERS?
It is our policy not to disclose any personal information about our customers or former customers to anyone, except as required by law (for example, when we are audited by regulators of the SEC). The only time we disclose your personal information to anyone else is at your request.
WHAT WOULD YOUR RIGHTS BE IF WE DID DISCLOSE YOUR PERSONAL INFORMATION TO OTHERS?
If our policies were to change and we sought to disclose your personal information to others, we could not do so without your permission. Under those circumstances, you would have the right to "opt-out" of our disclosing that information. In other words, you would be able to tell us that we could not disclose the information to any other person or entity. Since we do not currently disclose any of your information to anyone, you do not need to avail yourself of the right to opt-out.
Should our policies change, we would provide you with detailed information prior to implementing any potential change and request your approval to do so. At that time, we would also provide you with information on how you would be able to opt-out of us disclosing information about you.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION THAT WE HAVE IN OUR FILES?
We have adopted strict policies and procedures to protect your personal information. We restrict access to your information to our personnel who require it to provide you with our services. We maintain physical (such as locked cabinets), electronic (such as computer passwords), and procedural safeguards to protect your personal information. We maintain a secure office and computer network environment to ensure information is not placed at unreasonable risk. We back up our computer systems daily.
WHAT SHOULD I DO WITH THIS NOTICE?
First, don't be alarmed. As we indicated above, all registered investment advisers are subject to Regulation S-P and all are required to make a similar notice to their clients. We suggest that you keep this notice with your files. Finally, do not hesitate to contact us if you have any questions regarding this notice, or if you have any other questions.