
PRIVACY POLICY
Last Updated: January 1, 2026
Investment advisers are required by law to inform their clients of their policies regarding the privacy of client information. We are also bound by professional standards of confidentiality that are more stringent than many legal requirements. Federal law gives customers the right to limit some, but not all, sharing of personal information. This notice explains how we collect, share, and protect your personal information.
1. TYPES OF NONPUBLIC PERSONAL INFORMATION (NPI) WE COLLECT
We collect nonpublic personal information (“NPI”) about you that is provided by you, and/or obtained with your authorization, in connection with providing advisory services. This may include, but is not limited to:
Social Security Number
Date of Birth
Banking information
Financial account numbers and/or balances
Sources of income
Credit card numbers or related information
When you are no longer our customer, we may continue to share your information only as described in this notice.
2. PARTIES TO WHOM WE DISCLOSE INFORMATION
All investment advisers may need to share personal information to run their everyday business. We may disclose NPI as permitted by law for the following purposes:
For everyday business purposes, such as to process transactions, maintain account(s), respond to court orders and legal investigations, or as otherwise required by law.
For our marketing, to offer our products and services to you.
For joint marketing with other financial companies, where permitted and applicable.
For affiliates’ everyday business purposes, including information about your transactions and experiences and information about your creditworthiness (where applicable).
For affiliates and non-affiliates to market to you, where permitted and applicable.
If you are a new customer, we may begin sharing your information on the day you sign our agreement. When you are no longer our customer, we may continue to share your information as described in this notice. You can contact us at any time to limit sharing as described below.
3. IMPORTANT MOBILE AND SMS PRIVACY DISCLOSURES
To comply with carrier and messaging requirements, we provide the following mobile specific disclosures:
No mobile information will be shared with third parties or affiliates for marketing or promotional purposes.
Text messaging originator opt-in data and consent will not be shared with any third parties, except for aggregators and providers of the text messaging services needed to deliver messages.
If this Privacy Policy describes sharing personal information in other contexts, all the above categories exclude text messaging originator opt-in data and consent and that information will not be shared with third parties, excluding aggregators and providers of the text messaging services.
4. HOW WE OBTAIN SMS CONSENT
If you choose to receive text messages from us, we obtain your consent in one or more of the following ways:
By you submitting your phone number through an online form and affirmatively checking an SMS consent checkbox (not prechecked).
By you providing your phone number and consent through other written or electronic methods that clearly disclose you are agreeing to receive texts (for example, intake forms, onboarding forms, appointment requests, or similar).
Where applicable, by you initiating contact via SMS and confirming you want to receive texts from us.
Message frequency may vary. Message and data rates may apply.
To opt out at any time, reply STOP. For help, reply HELP.
5. COOKIES AND TRACKING PRACTICES
We use cookies and similar technologies (such as pixels and tags) to operate our website, understand usage, and improve marketing performance.
What we use
Essential cookies needed for website functionality.
Analytics cookies to understand traffic and usage patterns (for example, page views, time on site, referral sources).
Advertising and tracking technologies that may help us measure the effectiveness of marketing and deliver relevant ads (for example, conversion tracking pixels).
What data may be collected
Depending on your browser settings and cookie choices, these technologies may collect information such as device identifiers, IP address, browser type, pages visited, and actions taken on the site.
Your choices
Most browsers allow you to control cookies through settings (including blocking or deleting cookies). If you disable cookies, some website features may not function properly.
6. PROTECTING THE CONFIDENTIALITY OF CURRENT AND FORMER CLIENT INFORMATION
To protect your personal information from unauthorized access and use, we use security measures that comply with applicable law, including computer safeguards and secured files and facilities.
7. YOUR RIGHT TO LIMIT SHARING (OPT OUT)
Federal law allows you the right to limit the sharing of your NPI by opting out of:
Sharing for affiliates’ everyday business purposes information about your creditworthiness (where applicable), and/or
Sharing with affiliates or non-affiliates who use your information to market to you (where applicable)
State laws and individual companies may provide additional rights to limit sharing. Please notify us if you choose to opt out of these types of sharing.
8. DEFINITIONS
Affiliates: Companies related by common ownership or control. They can be financial and non-financial companies.
Non-affiliates: Companies not related by common ownership or control. They can be financial and non-financial companies.
Joint marketing: A formal agreement between non-affiliated financial companies that together market financial products or services to you.
9. QUESTIONS
Please contact us if you have any questions. Your privacy, our professional ethics, and our ability to provide you with quality financial services are very important to us.