Federal privacy laws enacted in 2001 require that we explain to you how we handle “nonpublic personal information.” This is information that in the course of our relationship with you, we receive or develop about you. It includes (1) information you provide to us orally or on contracts or other forms, and (2) information we develop about you in the course of providing our services to you, such as the amount and type of your assets that we manage and transactions we place on your behalf.


As a general rule, we do not disclose this private information to others. However, we rely on certain third parties for services that are necessary to enable us to provide our investment services to you. These may include our attorneys, auditors, accountants, brokers, custodians and other consultants who, in the ordinary course of providing their services to us, may require access to information containing your nonpublic personal information. In addition, there may be circumstances in which applicable law or regulations relating to combating terrorism or money laundering may require the release of nonpublic personal information to law enforcement or regulatory officials. We may also disclose your nonpublic personal information to regulatory bodies or other parties as necessary or appropriate, to establish the availability of exemptions from certain securities and similar laws or our compliance with applicable laws, where required by law or judicial process (such as a court order), to others with your consent, or otherwise to the extent permitted under the federal privacy laws.


We maintain safeguards at our facilities to provide reasonable protection of the confidentiality of our clients (including former clients), and limit access to your nonpublic personal information to those employees who need the information in order to help us provide services to you. It is our policy that, where we are not comfortable that a service provider is already bound by duties of confidentiality (e.g., attorneys and auditors), we will require contractual assurances that they will maintain the confidentiality of any of your information they obtain. We also maintain physical, electronic and procedural safeguards to guard your nonpublic personal information.


If you have any questions about our practices with respect to your nonpublic personal information, you may contact us by telephone at (650) 572-9469.