We collect nonpublic information about you from the following sources:

• Information we receive from you on applications or other forms; such as, your name, address, social security number, assets and income

• Information about your transactions with us, our affiliates, or others for which you approve access.

• Information you provide us during meetings, telephone calls or emails.

CATEGORIES OF INFORMATION WE DISCLOSE

We do not disclose any nonpublic personal information about our investors or former investors to anyone, except as required by law.

We restrict access to nonpublic information about our clients to employees and other parties (such as our accountants and service companies providing administrative or account services to us) who need to know that information in order for us to provide our services. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard our clients' nonpublic personal information.