Federal privacy laws require that we explain to you how we handle nonpublic personal information. It is information that in the course of our relationship with you, we receive or develop about you. It includes information you provide to us orally or on applications or other forms and information we develop about you in the course of providing our services to you.
We do not disclose this private information to others. However, we rely on certain third parties for services that are necessary to enable us to provide our investment services to you. These may include auditors, prime brokers, and custodians who, in the ordinary course of providing their services to us, may require access to information containing your nonpublic personal information. In addition, we may disclose your nonpublic personal information to others with your consent, where required by law or judicial process (such as a court order), or otherwise to the extent permitted under the federal privacy laws.
We restrict access to your nonpublic personal information among our personnel. Only those who need the information in order to help us provide investment advisory services to you have access. When a service provider is not already bound by duties of confidentiality (e.g. attorneys and auditors) we will require contractual assurances that they will maintain the confidentiality of any of your information they obtain. We also maintain physical and electronic safeguards to guard your nonpublic personal information.
Last updated and effective as of: May 24, 2018