Our clients share sensitive financial information, and we are committed to honoring each client’s right to privacy by keeping that information safe and secure.
The following points are designed to safeguard the privacy of every client:
- Limitations on Collection and Use of Information. In order to provide quality investment management services to our clients, occasionally we may need information from outside sources with which the client has a relationship. We will limit the collection and use of client information to what is necessary to manage a client’s financial affairs, and we will not seek financial information from third parties without first obtaining client permission.
- Restrictions on Disclosure of Information. It is a priority of the Company to limit the use of client information to individuals within our firm. Except under the circumstances discussed below, we will not reveal information about a client’s account to any person or entity outside of The Company, including any other affiliated company or person, unless a client grants us permission to do so. The exceptions are situations where:
- the information is furnished to third parties to complete a necessary transaction or otherwise to provide an essential function in the administration or management of a client’s account at The Company;
- the information is shared with a trust company which also has a relationship with the client;
- the information is required to be disclosed by law (e.g., a request for information by a governmental agency); and
- the information is provided to affiliated companies for management purposes (e.g., audit, accounting, board of directors).
- Client Privacy with Service Providers. As indicated above, from time to time, we may need to provide client information to third-party service companies that we have hired to complete an account transaction or to service a client account. The Company will engage only those service companies that agree to keep client information confidential and that maintain safeguards and privacy procedures consistent with those of our Company.
- Limitations on Employee Access to Information. The Company employee access to client information is limited to those who have a business reason to know that information. Our employees understand that all information, without exception, must be kept strictly confidential.
- Computer and Internet Safeguards. The Company has established additional security standards and procedures to secure client information. These procedures may be evaluated by an outside vendor to ensure that the information technology protections employed by The Company meet industry standards in today’s rapidly changing data security environment.