COMMITMENT TO PRIVACY

We consider privacy to be fundamental to our relationship with our clients. In the course of providing products and services to our clients we collect non-public personal information about them. We collect this information from sources such as account applications, personal and phone conversations and other forms of information captured on our website.

We do not disclose any non-public personal information about clients or former clients to non-affiliated parties, except as directed by clients as necessary. Your information is used by us or our service providers primarily to complete transaction or account changes that you request or authorize. In the normal course of serving clients information we collect may be shared with companies that perform various services for us, such as transfer agents, custodians, proxy solicitation forms, or printers or mailers that may assist us in the distribution of investor materials. The organizations that receive client information receive only the information necessary to carry out the services required. In addition, such organizations are not permitted to share or use this information for any other purpose and are required to treat client information with the same high degree of confidentiality maintained by us.

We do not sell or distribute client information to anyone other than that necessary to transact business solely on your behalf.

We may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required or permitted by law (for example, to cooperate with regulators or law enforcement authorities, or to protect accounts from fraud).