- The Firm is committed to protecting the confidentiality and security of the information it collects and will handle customer and consumer information only in accordance with Regulation S-P and any other applicable laws, rules and regulations. The Firm will ensure: (a) the security and confidentiality of customer records and information; (b) that customer records and information are protected from any anticipated threats and hazards; and (c) that customer records and information are protected from unauthorized access or use.
- The Firm conducts it business affairs through its principals, employees and third parties that provide services pursuant to agreements with the Firm or its clients. The Firm will safeguard customer information and only permit appropriate and authorized access to and use of customer information by its principals and employees through the application of appropriate administrative, technical and physical protections.
- The Firm may share customer information with unaffiliated third parties only in accordance with the requirements of Regulation S-P. Pursuant to this policy, the Firm will not share customer information with unaffiliated third parties other than as permitted by law, unless authorized to do so by the customer.
- The Firm does not presently obtain “consumer report information” as such term is defined in Regulation S-P. If the Firm should obtain “consumer report information,” it will comply with the disposal rules set forth in Regulation S-P.
Adopted February 2011