(Effective November 2005)
Information We Collect. "Nonpublic personal information" is personally identifiable financial information about you or your family. The kind of nonpublic personal information we have about you includes the information you provide us with when you open your account or when we discuss your account with you. In the course of providing products and services to you, we collect nonpublic information about you from various sources such as account applications or agreements, other account forms, transactions in your account, and from information that may be captured from our website. This information includes but is not limited to: your name, address, telephone number, family, your employment as well as your personal financial details and investment objectives. We also have information about your account assets, financial transactions as well as brokerage and custodial arrangements for your account.
Information We Disclose. We will only disclose nonpublic personal information about you to those persons and entities that provide necessary services to your account or upon your specific authorization and as permitted by law. Information we collect may be shared with companies that perform various services for you, such as custodians, broker-dealers and back-office administration and customer service firms.
How We Keep Your Information Safe. We restrict all access to nonpublic personal information about you to only those persons or entities that need it to provide services to you or who are permitted by law to receive it. We use industry customary physical, electronic, and procedural safeguards to protect client information. Such safeguards include password-required access to on-line client reporting system, data encryption, and security systems. A client's right to privacy extends to all forms of contact with us, including telephone, written correspondence and electronic media, such as the Internet.