We respect the privacy of all our clients and prospective clients, both past and present. We recognize that you have entrusted us with non-public personal information and it is important to us that all employees and clients of our firm know our policy concerning what we do with that information.

We collect personal information about our clients from the following sources:

• Information our clients provide to us to complete their financial plan or investment recommendations;

• Information our clients provide to us in agreements, account applications, and other documents completed in connection with the opening and maintenance of their accounts;

• Information our clients provide to us verbally; and

• Information we may receive from service providers, such as custodians, about client transactions.

We do not disclose non-public personal information about our clients to anyone, except in the following circumstances:

• When required to provide services our clients have requested;

• When our clients have specifically authorized us to do so;

• When required during the course of a firm assessment (i.e., independent audit); or

• When permitted or required by law (i.e., periodic regulatory examination).

Within our firm, we restrict access to client information to staff that need to know that information. All personnel and our service providers understand that everything handled in our offices are confidential and they are instructed to not discuss client information with someone else that may request information about an account unless they are specifically authorized in writing by the client to do so. This includes providing information about a spouse’s IRA or to children about their parents’ accounts.

To ensure security and confidentiality, we maintain physical, electronic, and procedural safeguards to protect the privacy of client information.

The firm will provide clients with our privacy policy on an annual basis and at any time, in advance, if firm privacy policies are expected to change.