We consider privacy to be a fundamental aspect of our relationship with clients1. We are committed to maintaining the confidentiality, integrity and security of our current, prospective and former clients' personal information at all times. As a result, we have developed policies to protect personal information without sacrificing the effectiveness of our service and performance with each client.
In the course of providing advisory services, we will obtain non-public, personal information about each client. This information may come from sources such as account applications, confidential questionnaire's, brokerage or financial advisory firms, financial advisors or consultants or information gathered through our website. Information may come in written, electronic or verbal correspondence or transactions.
We do not disclose any personal information provided by our clients or gathered through non-affiliated third parties, except as required or permitted by law. It is not typical for our firm to use any non-affiliated third party that would require the release of personal information. However, we may provide personal information to a client's brokerage or financial advisory firm and/or financial adviser or consultant relevant in the management of their investment assets.
We reserve the right to disclose or report personal information to non-affiliated third parties in limited circumstance where we believe in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities, or to protect our rights or property. In addition, we may disclose information about client accounts to a nonaffiliated third party at a client's request, or if a client consents in writing to the disclosure. Our affiliates, in turn, are not permitted to share client information with non-affiliated third parties, except as required by law.
We take our obligation to safeguard non-public, personal information very seriously. We have implemented internal procedures designed to restrict access to our clients' non-public, personal information that personnel use to provide service to our clients. To guard non-public, personal information, we have established physical, electronic, and procedural safeguards.
Clients have the opportunity to request that their non-public, personal information not be shared with any non-affiliated third party by submitting a request to us in writing to "opt out". Clients have 30 days following the receipt of the initial Privacy Notice, and 30 days following the annual notice offer, to "opt out".
1 - Clients include those invested through separate accounts, sub-advisory relationships or limited partnerships.
