Privacy Policy


In compliance with the Securities and Exchange Commission's Regulation S-P (Privacy of Consumer Financial Information), which was adopted to comply with Section 504 of the Gramm-Leach-Bliley Act  disclosures to clients its policies and procedures regarding the use an safekeeping of personal information.

An Adviser collects personal, private information form its clients for a number of reasons, including, determining clients' financial goals and adequately servicing clients' accounts from within adviser and with adviser's service providers (i.e.- custodians, and other financial firms).  Adviser strictly forbids client information to be provided to anyone outside of adviser.  Adviser understands the importance of safeguarding client information and maintaining the privacy of its clients.  Adviser's privacy policy is set forth as follows:

Adviser does not provide client information to anyone, unless expressed below.  Client information is only given to broker / dealer to open brokerage accounts, other firms as directed by client, such as accountants, lawyers etc., specified family members, and to regulators when required by law.

Personal information is collected from clients at the inception of their accounts and updated periodically, primarily to determine accounts' investment objectives and financial goals.

Access to clients' personal information is restricted to individuals within adviser firm that require the information in the ordinary course of servicing clients' accounts.  Client information is used only for business purposes.  Adviser utilizes physical, electronic and procedural safeguards to protect clients' information.  Such safeguards are detailed further in adviser's policies and procedures.  While adviser strives to update changing client information on a regular basis, we expect clients to monitor any information provided to them by adviser for errors.  At times, client information may be reviewed by adviser's outside service providers (i.e. - accountants, lawyers, consultants, etc.).  Adviser will review the entities' privacy policies to ensure that clients' information is not misappropriated or used on a manner that is contrary to the advisers's privacy policies.  In the event that that these policies change, adviser will provide its clients with a sufficient amount of time to opt out of any disclosure provisions.  Nevertheless, adviser shall provide a copy of its annual privacy notice to clients upon inception of the relationship.  in addition, each of advisers active clients shall be provided with a copy of the privacy notice within 90 days following the close of adviser's fiscal year.