PRIVACY

Regulatory Framework

We collect, use, and protect personal and confidential information in line with applicable state and federal privacy laws. Access to non-public personal information is limited, and we maintain safeguards meant to prevent unauthorized disclosure and to make our handling of client data transparent.

Safeguarding Information

We use electronic, physical, and procedural safeguards to store client information and limit unauthorized access. Those policies are reviewed and updated as laws and operations change. Members and associates are required to follow them.

Information Collection

We collect and use client information for legitimate business purposes: delivering services, running the firm, managing risk, describing our services, and meeting legal requirements. We may share information with affiliates or other parties when that sharing supports those purposes, when the law allows it, when a confidentiality agreement or internal policy permits it, or when the client consents.

Information Sharing

We may disclose client information as permitted or required by law, including to regulators and law-enforcement officials with jurisdiction over us, or when needed to address fraud. When we use third parties to provide services or make products available, those parties are contractually required to keep the information confidential and use it only as their agreement allows. We notify clients when information is shared with affiliates or third parties in these circumstances.

Third-Party Choices

Clients have choices about sharing information with affiliates and third parties, subject to applicable law and the terms of their agreement with us.