Privacy Policy

As a means of providing you with individual investment service, we collect the following nonpublic personal information about you:

• Information we receive from you on or in applications or other forms, correspondence or conversations.

• Information about your transactions with us, our affiliates, or others.

• Information we receive from you on or in investment suitability questionnaires provided directly to you by us through direct inquires by mail or telephone, or indirectly from third parties with your permission.

We do not disclose any nonpublic personal information about our current or former clients to anyone, except as permitted by law.  For example, we may disclose all of the information we collect, as described above, to financial service providers such as custodians and Separate Account Managers, and to administrative and marketing service providers such as printers and mailers, in an effort to help you meet your investing needs and to effect transactions you request or authorize.  We do not sell client lists or any other client information to outside companies.  Furthermore, we restrict access to your nonpublic personal information to those persons who require such information to provide products or services to you.  We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic personal information.