As general policy, the Firm will not disclose personal financial information about any client to non-affiliated third parties except as necessary to establish and manage the client’s account(s) or as required by law. In these situations, personal financial information about a client may be provided to the broker/dealer or other custodian maintaining these accounts. In addition, the Firm will restrict access to clients’ non-personal financial information to those employees who need to know such information in order to provide products or services to clients. The Firm will maintain physical, electronic and procedural safeguards that comply with federal standards to guard each client’s personal financial information. Each client will be provided with a copy of the Firm’s Privacy Notice upon opening his/her account. In addition, each active client of the Firm will be provided with a copy of the Privacy Notice within 90 days following the close of the Firm’s fiscal year.