The Investment Advisor Customer Privacy Policy

In November of 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA). The GLBA requires certain financial institutions, such as investment advisor firms, to protect the privacy of customer information. In situations where a financial institution does disclose customer information to nonaffiliated third parties, other than permitted or required by law, customers must be given the opportunity to opt out or prevent such disclosure. The Investment Advisor does not share or disclose customer information to nonaffiliated third parties except as permitted or required by law. The Investment Advisor is committed to safeguarding the confidential information of its clients. The Investment Advisor holds all personal information provided by clients in the strictest confidence and it is the objective of The Investment Advisor to protect the privacy of all clients. Except as permitted or required by law, The Investment Advisor does not share confidential information about clients with nonaffiliated parties. In the event that there were to be a change in this policy, The Investment Advisor will provide clients with written notice and clients will be provided an opportunity to direct The Investment Advisor as to whether such disclosure is permissible.

To conduct regular business, The Investment Advisor may collect personal information from sources such as:

1. Information reported by the Client on applications or other forms the Client provides to The Investment Advisor.
2. Information about the Client’s transactions implemented by The Investment Advisor or others.
3. Information developed as part of analyses or investment advisory services.

To administer, manage, service, and provide related services for client accounts, it is necessary for The Investment Advisor to provide access to customer information within the firm and to nonaffiliated companies with whom The Investment Advisor has entered into agreements with. To provide the utmost service, The Investment Advisor may disclose the information below regarding customers and former customers, as necessary to companies to perform certain services on The Investment Advisor’s behalf.

1. Information The Investment Advisor receives from the Client on applications (name, social security number, address, assets, etc).
2. Information about the Client’s transactions with The Investment Advisor or others (account information, payment history, parties to transactions, etc).
3. Information concerning investment advisory account transactions.
4. Information about the Client’s financial products and services transactions with The Investment Advisor.

Since The Investment Advisor shares nonpublic information solely to service client accounts, The Investment Advisor does not disclose any nonpublic personal information about The Investment Advisor’s customers or former customers to anyone, except as permitted by law. However, The Investment Advisor may also provide customer information outside of the firm as required by law, such as to government entities, regulatory bodies, consumer reporting agencies or other third parties in response to subpoenas, audits and reviews.