CUSTOMER PRIVACY POLICY NOTICE

Commitment to Your Private Information: (Firm Name) has developed a policy of protecting the confidentiality and security information we collect about our clients.  We do not, and will not, share nonpublic personal information about you (“Information”) with outside third parties without your consent, except for the specific purposes described below.  This notice has been provided to you to describe the Information we gather and the situations under which we need to share it. 

Why We Collect and How We Use Information.  We limit the collection and use of Information within our firm to only those individuals associated or employed with us that must have Information to provide financial services to you.  Such services include maintaining your accounts, processing transaction requests, providing financial planning, financial advisory, and other services described in our Form ADV.

Types of Information We Collect and How We Gather Information.  Client Information collected by our firm includes, but is not limited to the following:

• Information received from clients on financial inventories through consultations with our representatives. This information can include personal and household information such as income, spending habits, investment objectives, financial goals, statements of account and other records concerning the clients’ financial conditions and assets, together with information concerning employee benefits and retirement plan interests, wills, trusts, mortgages and tax returns.
• Information developed as part of financial plans, analyses or investment advisory services.
• Information concerning investment advisory account transactions and trades.
• Information about clients’ financial products and services transactions with our firm.
• Additional examples are listed below.

We get most Information directly from you when you provide us with information from any of the following sources:

• Applications or forms (for example: name, physical address(es), email address(es), phone number(s), social security number, birth date, assets, income, financial history)
• Transactional activity in your account (for example: trading history and account balances)
• Information services and consumer reporting sources (for example: to verify your identity or to assess your credit history)
• Other sources with your consent (for example: your insurance professional, attorney, or accountant)

How We Protect Information.  Our employees and affiliated persons are required to protect the confidentiality of Information and to comply with our stated policies.  They may access Information only when there is an acceptable reason to do so, such as to service your account or provide you with financial services.  Employees who violate our Privacy Policy are subject to disciplinary action, up to and including termination from employment with us.  We also maintain physical, electronic, and procedural safeguards to protect information, which comply with applicable SEC, state, and federal laws.

Sharing Information with Other Companies Permitted Under Law.  Information and advice furnished by (Firm Name) to you, is treated as confidential and not disclosed to affiliated or unaffiliated third parties, except as (1) permitted by you with written authorization, (2) shared in a manner necessary to facilitate the advisory services provided by (Firm Name) or (3) as required by any rule, regulation or law of any regulatory organization to which (Firm Name) or our investment advisor representatives may be subject. 

For example: you may ask (Firm Name) to provide information to your other services providers, such as your accountant, and we are pleased to be of assistance when you direct us to share information. Regulatory and self-regulatory bodies generally conduct routine audits of investment advisers to review books and records, and in the process may review client information.  Additionally, your account custodians and their personnel will have access to and review client data for their internal purposes.

Former Customers.  Even if we cease to provide you with financial products or services, our Privacy Policy will continue to apply to you, and we will continue to treat your nonpublic information with strict confidentiality.

Delivery Methods.  A copy of this CUSTOMER PRIVACY POLICY NOTICE will be delivered to all clients in writing by at least one of the following methods:

• By hand delivering a copy to the client
• Mailing a copy to the client’s address on record
• If business is conducted electronically, a notice may be posted on an electronic site as long as the client acknowledges receipt of the notice prior to the client obtaining any services or products from (Firm Name)

A copy of the Privacy Policy Notice will be provided to the client no later than the time a client establishes a relationship with (Firm Name), unless this situation would cause a delay in the client obtaining services and the client agrees to accept the notice at a later date.  When this situation applies, a copy of the Privacy Policy Statement will be delivered to the client within a reasonable time period following the transaction.

Any time a change is made to the Privacy Policy, the statement to clients will be revised.  The revised statement will be given to all affected clients prior to any disclosure of information.