Information We Collect

We limit collection and retention to what’s needed to conduct business and deliver our services.

• Applications/forms (name, address, contact, SSN/TIN, DOB, employment, income, net worth)
• Banking, financial, investment, and tax details
• Business holdings, real estate, and related interests
• Account and transaction data with custodians (balances, activity, history)
• Consumer report information (e.g., credit reports)

How We Share

We do not disclose nonpublic personal information to non-affiliated third parties except as permitted by law and needed to serve you.

Permitted Exceptions

• Service providers (e.g., attorneys, auditors, brokers, custodians) under confidentiality and safeguards
• Processing/servicing transactions you request or authorize and maintaining your accounts
• As permitted/required by law (e.g., legal process, audits, fraud investigations)

If practices change in the future, we will implement opt-out procedures and provide updated disclosures.

Information Security Program

We maintain administrative, physical, and technical controls to help protect records and systems.

• Access limited to personnel with a need to know
• Locked rooms/cabinets for paper files; secure, password-protected servers
• Backups and archived/offline storage with protections
• Supervised disposal and shredding of paper; secure media destruction
• Up-to-date antivirus and firewalls

If you close or become inactive, we continue to follow this policy.

Other Notices

• Revisions: We will provide an updated notice upon material changes.
• Joint relationships: One notice may satisfy the requirement for joint account holders.
• Accuracy: You may contact us to correct incomplete or outdated information.
• Principles: These privacy principles guide our practices and do not modify existing agreements.

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