GDPR Privacy Notice



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:

  1. We collect personal information from you based upon the information that you have provided to us in our Investment Advisory Agreement, Account Information Form, and Investment Policy and Guidelines, from information that we collect when we effect transactions for you and from on-going conversations with you that allow us to provide asset management services to you based upon your needs and goals.
  2. We collect contact information and any information which allows us to perform our contractual services.
  3. We may also obtain information about you from third parties, custodians and other partners that we work with to provide our services.
  4. If you visit our website, we may collect information about your visit, including your email address, what pages you viewed or topics you searched for. This information allows us to continue to provide useful information to our clients.

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.