Privacy policy

Last updated: Jan 2025

We recognize the importance of protecting our clients’ privacy. We have policies to maintain the confidentiality and security of your nonpublic personal information. The following is designed to help you understand what information we collect from you and how we use that information to serve your account.

Categories of Information We May Collect

In the normal course of business, we may collect the following types of information:

  • Information provided by you: This includes subscription documents and other forms (including name, address, Social Security number, date of birth, income, and other financial-related information).
  • Transaction data: Data about your transactions with us, such as the types of investments you have made and your account status.

How We Use Your Information

Any and all nonpublic personal information that we receive with respect to our clients who are natural persons is not shared with non-affiliated third parties (that are not service providers to us) without prior notice to, and consent of, such clients, unless otherwise required by law.

Authorized Disclosures:

  • Service Providers: We may disclose information to non-affiliated third-party service providers involved in servicing and administering products on our behalf (e.g., administrators, auditors, and legal advisors).
  • Legal & Regulatory: We may disclose information as required by law (such as responding to a subpoena), to satisfy requests from regulators, or to prevent fraud.
  • Anti-Money Laundering: We may disclose information to governmental entities to meet obligations under the USA PATRIOT Act of 2001 and related regulations.

Data Disposal:If we choose to dispose of nonpublic personal information that we are not legally bound to maintain, we will do so in a manner that reasonably protects such information from unauthorized access. This policy also applies to former clients who are natural persons.

Confidentiality and Security

We restrict access to nonpublic personal information to those employees and agents who need to know that information to provide products and services to you. To ensure your protection, we:

  1. Maintain physical, electronic, and procedural safeguards.
  2. Work diligently to maintain the trust you have placed in us.
  3. Remain committed to respecting your privacy as provided herein.

Contact Us

If you have any questions regarding this privacy notice, please contact us.