This notice describes how we handle your personal information and the steps we take to protect your privacy. Federal law gives consumers the right to limit some, but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. We call this information “customer data” or just “data”.  Please read this policy carefully to understand what we do.

Protecting Customer Data

We maintain physical, electronic and procedural safeguards to protect customer data. The only persons authorized to have access to it are those who need access in order to do their jobs. We require them to keep all data secure and confidential.

Information We Collect

We collect data you give us and data about the products and relationships you have with us so that we can serve you. It includes, for example:

• Your name and address
• Income, financial data and Social Security number
• Account numbers

We also collect data others give us about you, for example:

• Medical information on insurance applications
• Consumer reports from consumer reporting agencies

Sharing Data

We do not disclose any nonpublic personal information about you to anyone, except as permitted by law.  Such disclosure may include the following:

• Disclosures to affiliates, including affiliated service providers (for example, insurance agencies for processing of variable insurance applications on your behalf);
• Disclosures to your chosen qualified custodian or broker-dealer firm (for example, to establish a brokerage account on your behalf);
• Disclosures to government agencies, securities regulators and law enforcement officials (for example, for tax reporting, under a court order or to protect our legal rights);
• Disclosures to other organizations, with your consent (for example, other investment advisor firms in order to open a managed account with their firm or the brokerage firm they utilize); and
• Disclosures to other persons you authorize to obtain such information (for example, a CPA who will be preparing your tax return).

We will continue to adhere to the privacy policies and practices as described in this notice if you decide to close your account(s) or become an inactive customer.

If you have any questions concerning our privacy policies and procedures, please feel free to contact us.

Thank you.