PRIVACY STATEMENT

Securities & Exchange Commission Regulation S-P

We recognize the importance of protecting your privacy and we have policies in place to maintain the confidentiality and security of your personal information. The following policy is designed to help you understand what information we collect from you and how we use that information to serve your account.

Confidentiality and Security

We restrict access to nonpublic, personal information about you to those employees and agents who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards to protect your nonpublic, personal information. We do not disclose any nonpublic, personal information about our customers, potential customers or former customers to anyone, except as permitted by law. However, you agree that, unless you notify us otherwise in writing, we may reveal the performance or portfolio composition of your account in a manner which does not reveal your identity.

Categories of Information That We Collect
We collect nonpublic, personal information about you from the following sources:

  • Information we receive from you on a Confidential Investor Profile
  • Information we receive from you on New Account applications, Subscription Agreements, or other forms
  • Information about your transactions with us, our affiliates, or others