Information for Clients

Your privacy has always been important to us and we are committed to protecting your personal and financial information.

As your investment adviser, we collect non-public information about you from applications and other forms submitted to us by you or submitted to us through your financial consultant, custodial bank, or other authorized representatives (such as your accountant or attorney).

We regard non-public information to be data such as your name, social security number, date of birth, assets and income.

We will not disclose non-public information about you to anyone, except: as necessary to carry out transactions you have requested or authorized in connection with our provision of services to you; as required by law; in connection with a government or self-regulatory organization request or investigation; to non-affiliated third parties who assist us in administering client account; or with your expressed consent.

We restrict access to your personal and account information to those employees who need to know that information to provide services or products to you and to non-affiliated third parties who assist us in administering client accounts under contracts that prohibit them from delivering or using that information other than to carry out the disclosed purpose as your fiduciary.

Our privacy policy applies ot current, future and past clients. If you decide to close your account(s) or become an inactive client, we will adhere to the privacy policies and practices as described in this notice.

We maintain safeguards to guard your non-public personal information, including the disposal of this confidential information when necessary.

Information for Website Visitors

Analytics

This website collects personal data to power our site analytics, including:

• Information about your browser, network, and device

• Web pages you visited prior to coming to this website

• Your IP address

This information may also include details about your use of this website, including:

• Clicks

• Internal links

• Pages visited

• Scrolling

• Searches

• Timestamps

We share this information with Squarespace, our website analytics provider, to learn about site traffic and activity.

Cookies

This website uses cookies and similar technologies, which are small files or pieces of text that download to a device when a visitor accesses a website or app. For information about viewing the cookies dropped on your device, visit The cookies Squarespace uses.

• These functional and required cookies are always used, which allow Squarespace, our hosting platform, to securely serve this website to you.

• These analytics and performance cookies are used on this website, as described below, only when you acknowledge our cookie banner. This website uses analytics and performance cookies to view site traffic, activity, and other data.

By using this website, you agree to our use of cookies. We use cookies to provide you with a great experience and to help our website run effectively.

Webforms

When you submit information to this website via webform, we collect the data requested in the webform in order to track and respond to your submissions. We share this information with Squarespace, our online hosting provider, so that they can provide website services to us. We also share this information with our email provider for storage.

Fonts

This website serves font files from and renders fonts using Google Fonts and Adobe Fonts. To properly display this site to you, these third parties may receive personal information about you, including:

• Information about your browser, network, or device

• Information about this site and the page you’re viewing on it

• Your IP address

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Please direct questions about this privacy policy and these notices to Robert A. DeFruscio via the contact page.