Effective Date: January 1, 2021

1. Information We Collect

We collect non-public personal information including:

• Name, address, email, phone number, date of birth
• Social Security or taxpayer ID number
• Employment, income, investment goals, and risk tolerance
• Account balances, holdings, and transaction history
• Data from applications, forms, and conversations

2. How We Use Your Information

We use your information to:

• Provide financial planning and investment advice
• Open and manage investment accounts
• Process transactions
• Communicate account updates
• Fulfill legal and compliance obligations

3. Information We Share

We do not sell your information. We may share it only with:

• Service providers like custodians, brokers, and software vendors
• Legal or regulatory authorities, when required by law
• Outside professionals with your written permission

All third parties must protect the confidentiality of your data.

4. Security and Confidentiality

We safeguard your data through:

• Secure servers and encryption
• Limited employee access
• Ongoing privacy and cybersecurity training for staff

5. Your Rights

You may:

• Review and correct your personal data
• Receive this Privacy Policy annually
• Be notified of future policy changes with opt-out rights (if applicable)

6. Former Clients

We continue to protect your information even after our advisory relationship ends.

7. Questions or Concerns

Acknowledgment