The Firm collects nonpublic personal information about its Clients from the following sources:
- Information the Firm receives from a Client in subscription documents or other related documents or forms;
- Information about a Client's transactions with the Firm or others; and
- Information the Firm may receive from a consumer reporting agency.
The Firm does not disclose any nonpublic personal information about its prospective, existing or former Clients to anyone, except as permitted by law and regulation.
The Firm restricts access to nonpublic personal information about its Clients to those employees and agents of the Firm who need to know that information in order to provide services to its Clients. The Firm may also disclose such information to service providers and financial institutions that provide services to the Firm. The Firm will require such third party service providers and financial institutions to protect the confidentiality of the Clients’ nonpublic personal information and to use the information only for purposes for which it is disclosed to them. The Firm may also disclose nonpublic personal information to regulatory authorities as required or permitted by applicable law. The Firm maintains physical, electronic, and procedural safeguards that comply with federal standards to safeguard the Clients' nonpublic personal information and which the Firm believes are adequate to prevent unauthorized disclosure of such information.