WHAT INFORMATION WE COLLECT
We collect certain nonpublic personal identifying  information about you. This information can include:  address, social security number, income, and information that you provide on applications or other  forms as well as communications (electronic,  telephone, written or in person) with you or your  authorized representatives (such as your attorney,  accountant, etc.).  

We also collect information about your brokerage  accounts and transactions (such as purchases, sales,  account balances, inquiries, etc.).

WHAT INFORMATION WE USE AND SHARE
All financial companies need to share customers’ personal information to run their everyday business.  We do not disclose the nonpublic personal information  we collect about our customers to anyone except:  (i) in furtherance of our business  relationship with them and then only to  those persons necessary to effect the  transactions and provide the services that  they authorize (such as broker-dealers,  custodians, third-party managers etc.);  (ii) to your regulatory or persons assessing  our compliance with industry standards  (e.g., professional licensing authorities,  etc.);  (iii) to firms that assist in servicing your  account and have a need for such  information, such as a broker, custodian,  attorney, accountant, or auditor; or  (iv) as otherwise provided by law.  We are permitted by law to disclose nonpublic personal information about you to governmental  agencies and other third parties in certain  circumstances (such as third parties that perform  administrative or marketing services on our behalf).

Third parties are prohibited from using or share the  information for any other purpose. If you decide at  some point to either terminate our services or become  an inactive customer, we will continue to adhere to our  privacy policy, as may be amended from time to time. Our policy is never to share, sell or distribute your  phone number to any third party without your explicit  consent, unless required by law. 

HOW WE PROTECT YOUR INFORMATION
We restrict access to your nonpublic personal  information to those employees who need to know that  information to service your account. We maintain  physical, electronic and procedural safeguards that  comply with applicable federal or state standards to  protect your nonpublic personal information.

CHANGES TO OUR PRIVACY POLICY 
Our policy about obtaining and disclosing information  may change from time to time. We will provide you  notice of any material change to this policy before we  implement the change.

QUESTIONS
If you have any questions concerning this privacy  policy, please contact us at (415) 523-6868.

February 2025