Investment advisers are required by law to inform their clients of their policies regarding the privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law.

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Federal law gives customers the right to limit some—but not all—sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information.

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Types of Nonpublic Personal Information (NPI) We Collect

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We collect nonpublic personal information about you that is either:

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• Provided to us by you, or

• Obtained by us with your authorization.

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This may include, but is not limited to:

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• Social Security Number

• Date of Birth

• Banking information

• Financial account numbers and/or balances

• Sources of income

• Credit card numbers or related information

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When you are no longer our customer, we may continue to share your information only as described in this notice.

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Parties to Whom We Disclose Information

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Investment advisers may need to share personal information to run their everyday business. Below are the reasons we may share your personal information:

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• For everyday business purposes – to process your transactions, maintain your accounts, respond to court orders and legal investigations, or report to credit bureaus.

• For our marketing – to offer our products and services to you.

• For joint marketing – with other financial companies.

• For our affiliates’ everyday business purposes – including information about your transactions, experiences, and creditworthiness.

• For non-affiliates to market to you.

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If you are a new customer, we may begin sharing your information on the day you sign our agreement. When you are no longer our customer, we may continue to share your information as described in this notice. However, you may contact us at any time to limit our sharing.

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Protecting Confidentiality of Current and Former Clients’ Information

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To protect your personal information from unauthorized access and use, we employ security measures that comply with federal law. These measures include:

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• Computer safeguards

• Secured files

• Restricted building access

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Federal Law Gives You the Right to Limit Sharing (Opting Out)

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Federal law allows you to limit the sharing of your NPI by opting out of the following:

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• Sharing for affiliates’ everyday business purposes (information about your creditworthiness).

• Sharing with affiliates or non-affiliates who use your information to market to you.

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State laws and individual companies may give you additional rights to limit sharing. Please notify us immediately if you choose to opt out of these types of sharing.

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Definitions

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• Affiliates – Companies related by common ownership or control. They can be financial and non-financial companies.

• Non-affiliates – Companies not related by common ownership or control. They can be financial and non-financial companies.

• Joint marketing – A formal agreement between non-affiliated financial companies that together market financial products or services to you.

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Questions?

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Please call us if you have any questions. Your privacy, our professional ethics, and our ability to provide you with quality financial services are very important to us.