Privacy Policy

We recognize the importance of protecting your privacy. We disclose your non-public personal information only to companies selected by us to provide clearing, execution and related services.
• We only disclose information that is essential to providing these services.
• We do not disclose any non-public personal information to any other third party without your permission except as permitted by law.
• We do not sell your personal information to anyone.

What categories of information do we collect and disclose?
1) Information from your application form such as your name, address, email address, birth date, social security number or passport number, income and occupation.
2) Transactional information such as trading history and account balances.
3) Information provided by you, your registered representative or investment advisor, such as investment objectives and experience, product preferences or account suitability.
4) In limited cases, information from consumer reporting agencies. We may disclose all of the information we collect, as described above.

To whom do we disclose personal information?
We may disclose non-public personal information to our service providers who help us process your transactions or assist us in maintaining or servicing your account. Such service providers include broker-dealers and custodians. These service providers have privacy polices regarding the information that we share with them on your behalf.

Currently we disclose information only to the Pershing, A BNY Securities Group Co. which is our clearing and execution firm. We do not share non-public personal information with any non-affiliated third party that does not provide services in connection with your account unless permitted by law. We do not share non-public personal information with joint marketers.

• We do not share any information about former customers. We do not sell your personal information to anyone.
• We may share non-public personal information with our affiliate, HB Asset Management, if you maintain an account with that entity.
• We may share personal information with non-public governmental or regulatory agencies only if requested or permitted by law.

How do we protect the confidentiality, security and integrity of non-public personal information?
We restrict access to your non-public personal information to our employees who need to know that information to provide service to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard and protect your personal information. We treat all client information confidentially at all times.

How do we allow you to “opt out” of information sharing?
The law allows you to “Opt Out” of certain kinds of information sharing. You may elect to opt out of sharing your non-public personal information with our affiliate, HB Asset Management, at any time by telling us not to share the information. If you require a change to your personal information, please contact your registered representative to update our records. We will advise you of any change in our privacy policy.