Protecting our customers’ private information is a top priority and, pursuant to the requirements of the Gramm-Leach-Bliley Act; we have instituted policies and procedures to ensure that customer information is kept private and secure.

We do not disclose any non-public personal information about our customers or former customers to any non-affiliated third parties, except as required by law.  Only in the course of servicing a client’s account, may we share some information with its service providers, such as transfer agents, custodians, broker-dealers, accountants, and lawyers.

We restrict internal access to non-public personal information about the client to those employees who need to know that information in order to provide products or services to the client.  As emphasized above, it has always been and will always be our policy never to sell information about current or former customers or their accounts to anyone.  It is also our policy not to share information unless required to process a transaction, at the request of a customer, or as required by law.

A copy of our privacy policy notice will be provided to each client prior to, or contemporaneously with, the execution of the advisory agreement.  Thereafter, we will deliver a copy of the current privacy policy notice to our clients on an annual basis.