We may collect the following types of ‘nonpublic personal information’ about you:

·         Information we receive from you on applications, investment advisory agreements and other documents;

·         Information you provide to us orally;

·         Information about your transactions with us or others.

‘Nonpublic Personal Information’ is nonpublic information about you that we obtain in connection with providing a financial product or service to you, such as that described in the examples above.

What Information We Disclose

We do not disclose any nonpublic personal information about you to anyone except in the following circumstances:  (1) when required to execute transactions for your account or otherwise to provide services you have requested; (2) when you have specifically authorized us to do so in writing; or (3) when permitted or required by law.

Confidentiality and Security

We restrict access to nonpublic personal information about you to authorized representatives of the firm.  We maintain physical, electronic, and procedural safeguards that comply with federal standards and regulations to guard your information.

We will continue to adhere to the privacy policies and practices described in this notice even after your account is closed or becomes inactive.