1. In the normal course of providing
you with investment advisory services, we collect personal information
about you from the following sources: Information we receive from
you on applications or other forms; from copies of brokerage statements
and other documents you may provide to us from time to time; and
from the transactions in your accounts that we manage.
2. We do not disclose any personal information about our clients or former clients to third parties, unless one of the following limited exceptions applies: We may disclose personal information to other entities if required in connection with processing or servicing your transactions or account(s), such as to your stock broker, a transfer agent or custodian; we may disclose or report personal information where we believe in good faith that disclosure is required or permitted under law, for example, to cooperate with regulators or law enforcement authorities, to perform authentication checks, or for institutional risk control. Outside of these exceptions, we will not share your personal information with third parties unless you have specifically asked us to do so.
3. We restrict access to personal information about you to those employees, if any, who need to know that information in connection with providing investment advisory services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.