Effective May 25, 2018, the European Union (EU) General Data Protection Regulation (GDPR) is in effect. The purpose of the GDPR is to protect all EU citizens from privacy and data breaches in a data-driven world and applies not only to organizations located within the EU, but also to those outside the EU that process and hold personal information of residents of the EU. This privacy notice is to help you understand what information we collect, how we use it and what choices you have about your information.
We collect information in a few different ways:
We use the information we collect to perform our investment advisory services in accordance with our signed agreement. We also use the information we collect to provide you with informative commentary through emails and mailings, periodically. In addition, we may use this information to contact you regarding any matters that relate to your account.
It is our policy not to disclose any nonpublic personal information about our clients or former clients to anyone. The only time we disclose your nonpublic personal information to anyone is at your request.
We will only use or share your information with your consent. If our policies were to change and we sought to disclose your personal information to others, we could not do this without your permission. Under those circumstances, you would have the right to “opt-out” of our disclosing that information. In other words, you would be able to tell us that we could not disclose information to any other person or entity. Should our policies change, we would provide you with detailed information prior to implementing any potential change to request your approval. At that time, we would also provide you with information on how you would be able to opt-out of us disclosing information about you.
Under the GDPR, you have the following rights in relation to your personal information:
We have adopted strict policies and procedures to protect your personal information and maintain physical, electronic and procedural safeguards that comply with Federal standards to guard your personal information that we hold. We do not store any personal information outside of the United States. As a general matter, it is (and has always been) our policy not to disclose information about you to any other party, and to maintain strict security over personal information about you in our possession.
This policy may be updated periodically. Any material changes will be communicated to you promptly. Finally, do not hesitate to contact us at any time if you have any questions regarding this notice or if you have any other questions.