Registered Investment Advisor

Notice of Privacy Policy

This notice is being provided by the Firm, because you are a customer.

We are committed to keeping the personal information collected from our potential,
current and former customers confidential and secure. The proper handling of personal
information is one of our highest priorities. We want to be sure that you know why we
need to collect personal information from you. We also want to explain to you our
commitment to protect the information you provide to us. We never sell your
information to any outside parties.

Client Information

We collect and keep only information that is necessary for us to provide services
requested by you and to administer your business with us. We may collect nonpublic
personal information:

• From you when you complete an application, data gathering forms, or other forms.
This includes information such as name, address, social security number, assets, income,
net worth, copies of financial documents and other information deemed necessary to
evaluate your financial needs and objectives.

• As a result of transactions with us, our affiliates, or others. This could include
transactions completed with us, information received from outside vendors to complete
transactions or to effect financial goals.

Sharing Information

We only share your nonpublic personal information with non-affiliated companies or
individuals as permitted by law, such as your representative within our firm, affiliated
securities firm, mutual funds, insurance companies, and other product vendors, or to
comply with legal or regulatory requirements. We also with your approval may share
information with your advisors, which can include your accountant and/or attorney.