Our Commitment to You

YOUR COMPANY NAME (“YOUR COMPANY NAME” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”).

Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything we can to maintain that trust. YOUR COMPANY NAME (also referred to as “we”, “our”, and “us”) protects the security and confidentiality of the personal information we have. We implement controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you.

YOUR COMPANY NAME neither sells your non-public personal information to anyone nor provides such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below.

Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy.

Why You Need to Know

Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account(s). Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information.

What information do we collect from you?

Driver’s license number

Date of birth

Social security or taxpayer-identification number

Assets and liabilities

Name, address and phone number(s)

Income and expenses

E-mail address(es)

Investment activity

Account information (including other institutions)

Investment experience and goals

What Information do we collect from other sources?

Custody, brokerage, and advisory agreements

Other advisory agreements and legal documents

Social security or taxpayer-identification number

Transactional information with us or others

Account applications and forms

Investment questionnaires and suitability documents

Other information needed to service account

Why You Need to Know

To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage, and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained in their responsibilities to protect Clients’ personal information.

We require third parties that assist in providing our services to you to protect the personal information they receive from us.

How do we share your information?

An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information.

Servicing our Clients

We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting.

Do we share?: Yes

Can you limit?: No

Marketing Purposes

YOUR COMPANY NAME does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where YOUR COMPANY NAME or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes.

Do we share?: No

Authorized Users

Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent(s) or representative(s).

Do we share?: Yes

Can you limit?: Yes

Information About Former Clients

YOUR COMPANY NAME does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients.

Do we share?: No

Changes to our Privacy Policy

We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.

Periodically we may revise this Policy and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing.

Any Questions?

You may ask any questions, voice any concerns, or obtain a copy of our current Privacy Policy by contacting us at YOUR PHONE NUMBER.