PRIVACY

Regulations

The Privacy Act of 1974, codified at 5 U.S.C. § 552a, establishes a framework governing the collection, maintenance, use, and dissemination of personally identifiable information held within systems of records maintained by federal agencies. In accordance with the Privacy Act, agencies are obligated to provide public notice of their systems of records by publishing such information in the Federal Register (e.g., DOJ Systems of Records). The Privacy Act prohibits the disclosure of information from a system of records without the individual’s written consent, except in cases where one of the twelve statutory exceptions applies. Furthermore, the Privacy Act affords individuals the right to request access to and amendment of their records and imposes specific record-keeping obligations on agencies to ensure compliance with its provisions.

Safeguarding

Protecting the privacy and confidentiality of our clients is a paramount priority for our firm. To this end, we rigorously comply with legal standards by implementing robust electronic, physical, and procedural safeguards designed to securely store and shield client information from unauthorized access and misuse. Our comprehensive policies and procedures are regularly reviewed and updated to maintain the highest standards of confidentiality and ensure adherence to all applicable laws, rules, and regulations. Every member and associate of our firm is held to the strictest standards of accountability in complying with these policies, procedures, and regulatory requirements.

Information Collecting

We collect and utilize client information solely for legitimate purposes that we believe facilitate the delivery of superior service, the management of our business operations, risk oversight, the promotion of our services and products, and compliance with all applicable laws and regulations. We may share certain client information with affiliates, business units, or other entities when we determine that such sharing will enhance the quality of services and products provided, or for legal and customary business purposes. However, any such sharing is conducted strictly in accordance with applicable laws, relevant confidentiality agreements, our internal policies and procedures, or with the express consent of the client.

Information Share

We may disclose client information as permitted by applicable law. For example, we may share information with regulatory authorities and law enforcement officials having jurisdiction over us, or when required by law to safeguard against fraudulent activities. From time to time, we enter into agreements with third-party entities to provide services or to make products and services available to our clients. In such cases, we may share client information, but the recipients are contractually bound to maintain confidentiality and to use the information exclusively for the purposes outlined in the respective agreements. We will notify our clients regarding the sharing of their information with our affiliates and/or other entities in these circumstances.

Third Parties

We will offer clients choices concerning the sharing of their information with affiliates and third parties, in compliance with applicable laws and the terms of their agreements with us.