Broker Check

Privacy Notice


April 11, 2022

Our Commitment to Privacy 

Our relationship with our clients is our most important asset. We strive to maintain your trust and confidence  in our firm, an essential aspect of which is our commitment to protect the confidentiality, integrity, and  security of your personal information. As we believe that all of our clients value their privacy, we do not  disclose your personal information to anyone unless it is required by law, or at your direction. We do not  sell your personal information to anyone. 

Personal Information That We Collect, Maintain, and Communicate 

We collect personal information so we can provide financial planning and investment advice services to  you. The types and categories of information we collect and maintain about you include: 

  •  Information we receive from you to provide financial planning and investment advice services  to you (such as your date of birth, social security number, address, telephone number, and  financial information); 
  • Information about your transactions with us or others to service your account (such as  investments bought or sold and account statements); 
  • Information that we receive from third parties with respect to your account (such as statements  from insurance or brokerage firms). 

In order for us to provide financial planning and investment advice services to you, we may disclose  personal information that we collect and maintain in very limited instances, which includes: 

  • Disclosures that are authorized or requested by you (for example, to receive an insurance or  annuity quote or a tax estimate); 
  • Disclosures that are required by law (for example, to cooperate with regulators or law  enforcement authorities); 
  • Disclosures to companies as otherwise permitted by law, including those necessary to service  your account (such as providing information to our staff). 

How We Protect Your Personal Information 

To fulfill our privacy commitment, we have instituted practices to safeguard the information that we  maintain about you. These include: 

  • Maintaining physical, electronic, and procedural safeguards that comply with federal and state  regulations to guard your personal information; 
  • Limiting access to personal information to employees and third parties that are necessary or  appropriate to provide services to you; 
  • Protecting information of our former clients to the same extent as our current clients.

Combatting Identity Theft with Proactive Measures 

Among the proactive measures that we may employ to protect our clients from identity theft are some or  all of the following: 

  • Conducting an annual meeting between the Chief Compliance Officer and personnel, which  acts as a forum to discuss the threat of identity theft and our procedures to safeguard client  information. 
  • Limiting the amount of nonpublic personal information collected from each client to an amount  reasonably necessary for us to accomplish its advisory duties. 
  • Limiting access to records containing nonpublic personal information to those persons who are  reasonably required to have access to such information during the normal course of their duties.
  • Requiring employees to report any suspicious or unauthorized use of customer information. • Limiting access to electronically stored nonpublic personal information to those persons having  a unique computer system log-in ID, and requiring that such persons change their log-in  passwords periodically. 
  • Involving our information technology department in the development of procedures to protect  electronic information. 
  • Implementing a data encryption package in all portable computers and devices to protect  personal information. 
  • Requiring all employees, third-party service providers, and independent contractors to enter  into a confidentiality and restrictive covenant agreement. 
  • Alerting clients to the dangers of identity theft as well as the need for them to protect their  confidential information. 
  • Establishing internal controls with respect to the flow of client information. 
  • Requiring terminated employees to return all records containing nonpublic personal  information, in any form, that may at the time of such termination be in the former employee’s  possession (including all such information stored in laptops, files, work papers, or portable  devices). 

Protecting Client Nonpublic Personal Information (NPPI) 

It is our policy to undertake reasonable measures to protect the unauthorized access or use of client non public personal information, including, but not limited to, consumer report information (collectively  referred to as “client information”), in connection with its disposal. To that end, we have established the  following procedures relative to the disposal of client information: 

  • All hard copy records containing client information shall be transferred to a format that cannot  practicably be read or reconstructed (e.g., through burning, pulverizing or shredding of papers,  etc.); 
  • All client information stored on electronic media shall be erased such that the information  cannot practicably be read or reconstructed; 
  • All employees shall be cross-trained in our client information disposal procedures.