BCP and Privacy Policy

We will not share nonpublic personal information about you with nonaffiliated third parties without your consent, except for specific purposes described below. This notice explains our collection, use, retention and security of information about you.

How We Gather Information: As part of providing you with financial products or services, we may obtain information about you from the following sources:

Account applications, forms, and other information that you provide to us, whether in writing, in person, by telephone, electronically or by any other means. This information may include your name, address, phone number, e-mail address, social security number, employment information, income, investment experience, and credit references; your transactions with us, or others. This information may include your account balances, positions, investment interests and history. We may also obtain information about you from reporting agencies. This information may include account information and credit history from public sources.

Sharing Information with Nonaffiliated Third Parties: We may disclose any non-public personal information about you to nonaffiliated third-parties without your consent when we believe it necessary for the conduct of our business, or as required or permitted by law, such as, to respond to a subpoena or court order, judicial process, law enforcement or regulatory authorities, to consumer reporting agencies, in connection with a proposed or actual sale, merger, or transfer of all or a portion of business or an operating unit, to help us prevent fraud.

In addition, we may disclose any nonpublic personal information about you to our service providers to help us process your applications or service your accounts, to enable them to provide business services for us, to facilitate the processing of transactions requested by you, to assist us in performing marketing services or offering products or services to you, for credit review and reporting purposes.

Except in specific, limited situations, without your consent, we will not make any disclosure of your non-public personal information to other companies who may want to sell their products or services to you. For example, we do not sell customer lists and we will not sell your name to a catalogue company.

Former Customers: Even if you are no longer a customer of the Firm, our Privacy Policy will continue to apply to you.

To Whom This Policy Applies: This Privacy Policy applies to individuals who obtain or have obtained a financial product or service from the Firm, used primarily for personal, family, or household purposes.

Our Security Practices and Information Accuracy: We also take steps to safeguard customer information. We restrict access to the personal and account information of our customers to our employees and agents for business purposes only. We maintain physical, electronic, and procedural safeguards to guard your personal information.

We also have internal controls to keep customer information as accurate and complete as we can. If you believe that any information about you is not accurate, please inform your registered representative.

Other Information: We reserve the right to change this Privacy Policy. The examples contained within this Privacy Policy are illustrations and they are not intended to be exclusive. If you have any questions about our Privacy Policy, please contact us.

Required Business Continuity and Contingency Planning Disclosure: Securities industry regulations require that registered Broker/Dealers inform their clients of their plans to address the possibility of a business disruption that potentially results from power outages, natural disasters, or other events. The Firm has a business continuity program which we review and update on a regular basis. The plan provides for continuation of client service by the beginning of the next day.

Here are a few examples of what might occur if we were to experience a business disruption of varying magnitude:

• Should our offices become unavailable for any reason, we would work from alternate locations until a new facility could be found.
• Should our electronic information become unavailable for any reason, we would restore our data from our backup facility.
• Should the power be unavailable in our business district, we would operate from another location with power, if possible. If the power outage is widespread, we would operate with reduced capability until power was restored.
• Should our office telephone numbers become unavailable for any reason, clients should contact us using our cell phone numbers.

While no contingency plan can eliminate all risk of service interruption, we periodically assess and update our plans to mitigate all reasonable risk.