As part of our business, we collect non-public information about our clients. We have an obligation to maintain the confidentiality of that information.
It is our policy to protect the privacy of our clients by following these principles:
- We do not disclose the names of our clients or information about them or their accounts, except with their consent or at their direction, as necessary to perform the services or to complete the transactions or tasks they have authorized, or as permitted or required by law
- Information about our clients and their accounts shall be reasonably safeguarded within our offices to avoid inadvertent disclosure.
- Access to information about clients shall be limited to our employees who have a business need to know it.
- We provide Privacy Notices as required by Reg S P.
- We have adopted and will maintain procedures reasonably designed to implement this policy and comply with the requirements of Reg S P.