Effective 01/01/17

The privacy practices of this Website Privacy Policy apply to our services available under the domain and subdomains of (the “Site”). We recognize that privacy is important to our users, so we design and operate our Site with the protection of your privacy in mind. This Privacy Policy outlines the types of personal information we may gather when you visit our Site or use our services, as well as some of the steps we take to safeguard it. Please read this Privacy Policy to learn more about the ways in which we protect, use and disclose your personal information. Our clients (“Investors”) receive the Firm’s Privacy Notice, describing our privacy policies and procedures applicable to their personal information that the Firm collects through means other than this Site. With respect to Investors, if this Website Privacy Policy and the Privacy Notice conflict, the Privacy Notice will govern.

By visiting the Site, you agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree, please do not use or access the Site.

By accepting the Privacy Policy and the Terms of Use, you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Terms of Use.

We may amend this Privacy Policy at any time by posting the amended terms on the Site. All amended terms will automatically be effective 30 days after initially posted on the Site. Your continued use of the Site constitutes your agreement to this Website Privacy Policy and any changes to this Website Privacy Policy. If you do not agree with this Website Privacy Policy or any changes to the Website Privacy Policy, please do not use or access the Site.


We have adopted general policies and procedures concerning confidentiality, proprietary data and privacy of customer personal information, and the information we gather over the Site is protected by those policies and procedures. Generally, we collect non-public personal information about our clients from the following sources:

  • Account applications and other forms;
  • Clients’ professional advisers such as attorneys and accountants;
  • Clients’ account history; and
  • Correspondence between us and our clients, their brokers and their custodians

We will not release information about you or your accounts to any third party unless one of the following conditions is met:

  • We receive your prior consent;
  • We believe the recipient is your authorized representative, including your attorney or accountant;
  • The recipient is a broker, custodian or other service provider with whom we must share information in order to manage your account properly; or
  • We are required by law to release the information to the recipient

We will only use information about you and your accounts to:

  • Help us better serve your investment and financial needs;
  • Suggest services or other materials that may be of interest to you; and
  • Administer our business

Our policy is that:

  • We do not disclose any non-public personal information about our clients or former clients to anyone, except as permitted by law.
  • We restrict access to non-public personal information about our clients to employees who need to know that information to provide services to our clients.
  • We maintain physical, electronic and procedural safeguards that comply with federal standards to guard clients’ personal information.


This Website Privacy Policy applies to information we collect through the Site. We do not presently collect any “personally identifiable information,” including any visitors’ names, addresses, phone numbers, social security numbers or email addresses, from the Site. In general, you can browse the non-password protected sections of the Site without telling us who you are or revealing any personal information about yourself.

However, we do automatically track certain information that your browser makes available whenever you visit a website. This information includes your Internet Protocol address, browser type, browser language and one or more files that may uniquely identify your browser. This information may include the URL that you just came from (whether this URL is on the Site or not), which URL you next go to (whether this URL is on the Site or not), your computer browser information and your IP address.

We also may use data collection devices such as “cookies” on certain pages of the Site to help analyze our web page flow, measure effectiveness, and promote safety. “Cookies” are small files placed on your hard drive that assist us in providing our services. We offer certain features that are only available through the use of a “cookie.” Cookies can also help us provide information that is targeted to your interests. Most cookies are “session cookies,” meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits.


We use the information we collect from our browser and data collection devices such as cookies to facilitate our operations and develop and improve content and our services. We may use this information to analyze Site usage and research our users’ demographics, interests and behavior so as to better understand and protect you and our clients. We may also use information collected from you to measure interest, enforce our Terms of Use, and customize the Site’s layout and services. These uses improve the Site and may better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Site.

We may also share information about you if we believe that disclosure is required under law. For example, we may need to disclose information in response to a subpoena or to cooperate with regulatory or law enforcement authorities.

We cannot ensure that all of your private communications and other personal information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting the foregoing), we may be forced to disclose personal information to the government or third parties under certain circumstances, and third parties may unlawfully intercept or access transmissions or private communications. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.


The Site may contain links to third party sites that are not owned or controlled by the Firm. The Firm is not responsible for the privacy practices of such other sites and we encourage you to read the privacy policies of each site that you visit from our Site.


Under California law, website service operators are required to disclose how they respond to web browser “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about a consumer’s online activities over time and across third party websites. At this time, the Firm does not track visitors’ personally identifiable information over time and across third-party websites and therefore this requirement does not apply to the Firm.


Your information is stored on our servers located in the United States. We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy, which may include encryption, “firewalls” and Secure Socket Layers. We treat data as an asset that must be protected against loss and unauthorized access. We employ security techniques to protect such data from unauthorized access by users inside and outside the company.

It is possible, however, that a third party will circumvent such security measures, and we do not guarantee that our security measures will successfully prevent third parties from accessing the information we collect. In the event of a security breach involving your personal information, we will make any legally required disclosures to you in the most expedient time possible and without unreasonable delay, consistent with the legitimate interests of law enforcement, or any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.


Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your username, password, credit card information or any identification number in an unsolicited email or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.


Children (persons under the age of 18) are not eligible to use the Site and, therefore, we do not knowingly collect any personal information from persons under the age of 18.


If you choose to visit the Site, your visit and any dispute over privacy is subject to this Privacy Policy and our Terms of Use, including limitations on damages and application of the law of the State of California. If you have any concern about privacy, please send a thorough description to Dominic Heil, our Chief Compliance Officer, at


We may amend this Privacy Policy at any time by posting the amended terms on the Site. All amended terms shall automatically be effective 30 days after they are initially posted on the Site. Your continued use of the Site constitutes your agreement to this Privacy Policy and any changes to this Privacy Policy. If we make any material changes to this Privacy Policy that affect your information already stored in our database, we will post a prominent notice on the Site stating that this Privacy Policy has changed. If you do not agree with this Privacy Policy or any changes to the Privacy Policy, please do not use or access the Site.

If you have any additional questions, please feel free to contact Dominic Heil, our Chief Compliance Officer, at