Privacy Policy

We consider your data to be private and confidential, and we hold ourselves to the highest standards of trust in their safekeeping and use.

We collect non-public personal information about clients such as you from the following sources:

Information we receive from you on applications, other forms, or telephone conversations with you;

Information about your transactions with us, our affiliates, or others, and

If you visit our Web site, information we collect via a Web server, often referred to as a “cookie.” Cookies indicate where a site visitor has been online and what has been viewed.

We do not disclose any non-public personal information about our customers or former customers to anyone, except as permitted by law. Moreover, we will not release information about our customers or former customers, unless one of the following conditions is met:

We receive your prior written consent.

We believe the recipient to be you or your authorized representative.

We are required by law to release information to the recipient.

We only use information about you and your account to help us better serve you or to suggest services or educational materials that may be of interest to you.

To protect your privacy, further, our Web site uses security programs and devices, which we believe to be in accordance with current business practices, including data encryption, user names and passwords, and other tools. We maintain physical, electronic and procedural safeguards to guard your personal account information. We also restrict access to your personal and financial data to authorized associates who have a need for these records. We advise you not to send such information to us in non-secure e-mails.

Confidentiality and Security

We maintain physical, electronic and procedural safeguards to guard your personal account information. We also restrict access to your personal and financial data to authorize associates who have a need for these records. We require all non-affiliated organizations to conform to our privacy standards and are contractually obligated to keep the information provided confidential and used as requested. Furthermore, we will continue to adhere to the privacy policies and practices described in this notice even after your account is closed or becomes inactive.

Protection of Customer Records

The Company has implemented the following measures to ensure the protection and confidentiality of customer information.

• Access to areas that house customer records shall be restricted only to employees who need access to such and to clients when accompanied by an employee.

• To the extent practicable, the Company will limit access to its offices where confidential information could be observed or overheard by individuals that do not need to know such information.

• To the extent practicable, the Company will limit access to its offices and areas where customer funds and securities are received and disbursed and where mail is received and distributed. The access shall be limited to the employees that are engaged in these activities and to their immediate supervisors. If possible, these areas shall be locked with access limited to the above referenced people who shall be issued keys or electronic passes.

• Firm personnel will be instructed to exercise care to avoid placing documents containing confidential information in areas where they may be read by unauthorized persons and store such documents in secure locations (i.e. locked files) when they are not in use.

• Company personnel are prohibited from discussing confidential information in public places such as elevators, hallways, restrooms, or at social gatherings.

• The Company shall require all non affiliated organizations that come into contact with non-public confidential information (lawyers, accountants, printers, etc.) to conform to its privacy standards and will contractually obligate them to keep the provided information confidential and used as requested.

• When documents containing non-public financial information are to be disposed, they shall be destroyed by shredding or some other secure manner, which can prevent readable copies from being used.

• All sensitive information that must be transported (physically or electronically) will be properly secured, either through the use of encryption or physical controls to prevent parties other than the intended recipient from viewing the contents.

• The Company will utilize locked shred bins and receptacles for employees to dispose of sensitive documents. Shred bins will be configured so that once materials are placed inside the materials cannot be retrieved. At no time will an employee place sensitive information “on” a shred bin or “in” a shred bin in such a manner that the information could be retrieved. If shred bins are full or unusable, employees must manually shred any sensitive information. The AML Compliance must ensure that shred bins will be emptied and their contents destroyed on a regular basis, via a shredding or document destruction service that will provide the Company with a proof of destruction certificate after each service call.

• Employees are instructed to maintain a “clear desk and clear screen,” working environment. If at any time sensitive information may be exposed to an unauthorized person, the employee will either clear the sensitive information from their desk (i.e., place the sensitive information in a drawer if a customer approaches, or turn a document face-down if another employee approaches), or they will clear their computer screen by removing the sensitive information from view (i.e., switching to an alternate screen or “minimizing” the active screen). Whenever an employee will be away from his or her work area for any amount of time (including breaks, lunch, end of day, restroom visits, etc), all sensitive information will be properly secured to prevent unauthorized access.

• Ensure that printers and faxes are cleared of any sensitive information immediately after printing or sending/receipt.

• All employees, including non-registered personnel, shall be apprised of these procedures when initially hired, and at the annual compliance meeting.

Should the Company suspect that an incident of identity theft has occurred or if it is notified by, a customer that they suspect an identity theft, the designated principal or his designee shall contact the Company’s legal department and compliance department. These departments shall commence an investigation and determine if an identity theft may have occurred. If the investigation determines that one may have occurred, Compliance and Legal shall notify the appropriate law enforcement agencies. (This includes the local Sheriff, the FBI, and Secret Service.)

The FTC serves as a clearinghouse for complaints against credit reporting agencies and credit grantors, referrals, and resources for assistance for victims of identity theft. They should be notified if the suspected victim requests this type of assistance. Refer to “Title 18 USC 1028” and to “Identity Theft and Assumption Deterrence Act of 1998”.)