This notice is provided to you in compliance with the Gramm-Leach-Bliley Act.
An essential element in the delivery of services to our Clients is fulfilling the trust our Clients extend to us. Insuring the Privacy and Security of the information we have about our Client’s assets, their personal situation and objectives is critical to our Mission as an Investment Advisor.
- We keep the personal information of our Clients in the strictest confidence.
- We do not provide personal information to anyone outside our firm without the express instructions of our Clients.
- We do not sell lists of our Clients; nor do we disclose Client information to marketing companies.
All the personal information we collect is obtained directly from our Clients, or from third parties at the express instructions of our Clients. This information is necessary for us to deliver services for which Clients contract. Information is most often provided us in direct conversations with Clients and/or upon their completion of applications for investment accounts that require name, address, Social Security numbers, dates of birth, and annual income. Information about transactions and security holdings is obtained from account statements or electronic downloads from custodians upon authorization from our Clients.
We will only divulge private information about our Clients appropriate in these situations:
- When such information is necessary for the establishment and maintenance of an investment account or for providing contractual services;
- When we must fulfill any legal or regulatory requirements imposed on us by the Securities and Exchange Commission and the Internal Revenue Service;
- At the Client’s request, to facilitate the tax planning by the Client’s accountant and filing tax returns;
- At the Client’s request, in response to inquiries from the Administrator of employee benefit programs; and
- To any other third party at the express written instructions of the Client.
Unless a client expressly instructs us not to, we will post investment account and limited confidential data to third-party software providers for Internet-portal access and financial planning tools. Using SSL/TLS protocols (public-key cryptology), we transfer this information over secure servers to ensure that others cannot view or intercept Client confidential information being transmitted over the Internet or stored in our databases. Security protocols for these third-party websites are established and maintained by these vendors who utilize such proven technology as 256-bit encryption on established server facilities like Amazon Web Services.
For information stored on servers under our direct control, we have implemented security standards and processes—including physical and electronic safeguards—to ensure that access to client information is limited to employees of our firm. We do not host at our offices any Internet website associated with our business. Remote access by employees to our network is achieved through VPN technology and a terminal server configuration using two-factor authentication. Confidential data is backed up each day to a geographically-remote data storage facility.
The third-party websites we have setup for our Clients can use “cookies”—a small data file that some web sites write to the user’s hard drive when visited—to keep track of a user during an on-line session by allowing their servers to synchronize the visit to the data being delivered to the user. These cookies do not store nor transmit any personally identifiable information about a Client when on the Internet.