To our Clients:

Your privacy is important to us. As a general rule, we do not disclose non-public personal information about our clients to anyone that is not affiliated with us without consent.

Types of "Non-Public Personal Information" We Collect

We may collect non-public personal information from you, from data or documents that you may deliver to us or from our discussions with you.

Persons to Whom We Disclose Information

As stated previously, we generally do not disclose any non-public personal information about our clients that we obtain during the course of our relationship to unaffiliated third parties, except as required by law. In order to conduct business, we may need to disclose this non-public personal information to unrelated third parties (for example, auditors, the Internal Revenue Service or other governmental entities). Also, in some situations, we may need to disclose or share non-public personal information with an affiliated third party. Your authorization to conduct business with us and your continuing relationship with us acts as your consent to our disclosure of your non-public personal information when such disclosure is necessary to conduct business.

In addition, we restrict access to non-public personal information to our employees who need to know the information. Your non-public personal information may also be shared with our attorneys, accountants and auditors. In all such situations, we take steps necessary to ensure that the confidential nature of the information being shared is maintained.

Protecting the Confidentiality and Security of Current and Former Investors' Information

In order to protect your information, we also maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your non-public personal information.