Client Confidentiality _____________________________________________________________________ We understand that we serve our clients using very sensitive, nonpublic personal information.  Protecting the privacy of our clients is our ethical responsibility and a firm imperative.  We have adopted these policies to protect the privacy of our clients. Secure Environment. When we collect nonpublic personal information about our clients in communications using questionnaires, agreements, applications and interviews with our clients or their advisors (accountant, attorney, etc.), we maintain that information in a secure environment and employees have access to this information based upon their responsibilities.  We may also collect and maintain information on behalf of our clients about their accounts with various financial institutions.  We also maintain this information in a secure environment and employees have access to this information based upon their responsibilities. No Information Sharing. We do not offer information about our clients to outside parties for marketing purposes.  With the permission of our clients, we may disclose information about them to others when it is necessary for others (such as broker-dealers, custodians, independent investment managers, lenders, accountants, attorneys, etc.) to effect transactions and provide services on behalf of our clients.  We must comply however, with state, federal, regulatory and judiciary requests as they assess our compliance with industry standards, laws and regulations. Third Parties. We may disclose nonpublic material information about our clients with third parties in certain circumstances, such as third parties that perform administrative, client support, accounting or legal services on our behalf.  These third parties are prohibited from using or sharing our client information for any other purpose. Term of Confidentiality. If one of our clients decides at some point to either terminate our services or become an inactive client, we will continue to adhere to our privacy policy on behalf of that client, as we may amend from time to time. Change in Policy. Our policies about obtaining, maintaining and disclosing nonpublic personal information may change from time to time.  We will provide our clients notice of any material change to our policies before we implement changes.  We continue to evaluate our efforts to protect the nonpublic personal information of our clients and make every reasonable effort to keep the information of our clients accurate and updated.