PRIVACY POLICY

PRIVACY POLICY

Our Commitment to Protecting Your Privacy

We consider customer privacy to be fundamental to our relationship with our clients.  In the course of operating and acting as a broker-dealer we collect personal information about you (“nonpublic personal information”).  We may collect this information to know who you are and to meet our obligations under the laws and regulations that govern us. 
Throughout our history we have been, and we remain, committed to maintaining the confidentiality, integrity and security of our clients’ personal information.  It is our policy to respect the privacy of our current and former clients and to protect the personal information entrusted to us.  This Privacy Policy describes the standards we follow for handling your personal information, with the dual goals of meeting your financial needs while respecting your privacy.

1. Information We Collect

We collect nonpublic personal information about you from three sources:

  • Information on subscription agreements or other forms.  This category may include your name, address, tax identification number, age, marital status, number of dependents, assets, debts, income, employment history, beneficiary information and personal bank account information.
  • Information from your transactions with us, such as your investment history.
  • Information obtained from others, such as consumer credit reporting agencies.

2. Information We Disclose

We may disclose any of the nonpublic personal information we collect to unaffiliated third parties only if necessary to operate and act as a broker-dealer.

For example, we may disclose nonpublic personal information about you to the unaffiliated third parties and in the circumstances described below, as permitted by applicable laws and regulations:

  • To companies with whom we have contracted to provide brokerage-related services.
  • To our lawyers, accountants, auditors, regulators, advisors, and quality-control consultants.
  • If we suspect fraud.
  • To protect the security of our records, Web site (if any), e-mail systems and telephone systems.
  • Information you have authorized us to disclose.

3. Protecting Your Information

We limit access to the information we have about you to our employees who need to know such information in order for us to operate and act as a broker-dealer.  In addition, we maintain appropriate physical, electronic and procedural safeguards to protect your information.

4. Former Clients

We treat information concerning our former clients the same way we treat information about our current clients.

5. Keeping You Informed

We will send you a copy of this Privacy Policy annually, as well as all changes to this Privacy Policy as they occur, if required by law or regulation.