PRIVACY STATEMENT

• We protect client information.
  We take our responsibility to protect the privacy and confidentiality of any client information very seriously. We maintain physical, electronic and procedural safeguards that comply with applicable legal standards to store and secure client information from unauthorized access and use, alteration and destruction. Our own policies and procedures have been developed to protect the confidentiality of client information and to help achieve compliance with relevant rules and regulations. We hold our employees accountable for complying with those policies, procedures, rules and regulations.
• We endeavor to collect, use and maintain client information only for appropriate purposes. We limit the collection, use and retention of client information to what we reasonably believe will help us deliver superior service, to administer our business, manage our risks, market our services and products, and to meet applicable laws and regulations. 
• We share client information with affiliates and with others when we believe it will enhance the services and products we can provide to clients or for legal and routine business reasons.
  • We share client information among our affiliates and business units when we believe it will enhance the services we can provide to clients, but only in circumstances where such sharing conforms to law, any applicable confidentiality agreements, our policies and practices, or where a client has consented to such sharing.
  • We may disclose information we have about clients as permitted by law. For example, we may share information with regulatory authorities and law enforcement officials who have jurisdiction over us or if we are required to do so by applicable law and to provide information to protect against fraud.
  • From time to time, we enter into agreements with other companies to provide services to us or make services and products available to clients. Under these agreements, the companies may receive information about clients, but they must safeguard this information and they may only use it for those purposes that we specify.
    
• We provide clients with relevant and appropriate choices regarding the sharing of information with our affiliates and others.
  We will give clients choices regarding the sharing of information with affiliates and third parties in accordance with applicable law and their agreements with us.
• We comply with the USA Patriot Act, Section 326. Please read this important information about procedures for opening a new account. 
  • To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.
  • What this means for you: When you open an account, we will ask for your name, address, date of birth (for individuals), and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.