Pursuant to the International Securities Standards and rules, financial institutions like the Advisor are required to provide privacy notices to their clients. The Advisor considers privacy to be fundamental to our relationship with our clients. We are committed to maintaining the confidentiality, integrity and security of our current and former clients’ non-public information. Accordingly, we have developed internal polices to protect confidentiality while allowing clients’ needs to be met.
We will not disclose any non-public personal information about clients, except as required by applicable law or regulation, and thus authorities will also have access to such non-public information and records. In the normal course of serving our clients, only needed and specific information may be shared with companies that perform various services such as our accountants, auditors and attorneys.
Specifically, we may disclose to these service provider’s non-public information required by law including:
Information that the Advisor receives from clients on managed account agreements and related forms (such as name, address, tax identification number, and birthdate, assets, income and investment experience); and:
Information about clients’ transactions with the Advisor (such as account activity and account balances).
Any party that receives this information will use it only for the services required and as allowed by applicable law or regulation, and is not permitted to share or use this information for any other purpose. To protect the personal information of individuals, we permit access only by authorized employees who need access to that information to provide services to our clients and us. In order to guard clients’ non-public personal information, we maintain physical, electronic and procedural safeguards that comply with the International Securities Standards. If the relationship between a client and the Advisor ends, the Advisor will continue to
treat clients’ personal information as described in this notice. An individual client’s right to privacy extends to all forms of contact with the Advisor, including telephone, written correspondence and electronic media, such as the internet.
The Advisor reserves the right to change this privacy notice, and to apply changes to information previously collected, as required by law. The Advisor will inform clients of any such changes as required by law.