privacy policy

Effective January 1, 2006

Background
As required by the rules and regulations of the Securities and Exchange Commission and the Federal Trade Commission, all financial services organizations are now required to provide their clients with their privacy policies. As an investment adviser, we have been — and continues to be — bound by professional standards of confidentiality.

Types of Non-Public Personal Information that we collect
In the ordinary course of business, and to perform our services effectively, we collect personal information about you that is provided to us by you or obtained by us with your authorization. This information is shared with us with the expectation that it is not to be disclosed to others. We deem this to be confidential information and we refer to it as “non-public personal information.”

In addition to personal information you provide to us, we may receive information about you that you authorize third parties to provide to us. This might include your accountant, tax advisor, attorney, banker, custodian, broker, or other third party whom you have authorized to talk with us. We also may obtain personal information from third parties in order to verify your identity and prevent fraud or to help us identify products and services that may benefit you.

Parties to Whom we Disclose Information
Advocate will not disclose personal financial information about any current or former client to non-affiliated third parties except as required and permitted by law.

The only instance in which we will share information about you is in the process of completing transactions in your account as part of our investment advisory services and exclusively with those financial institutions that have legal requirements to know about their customers or their customers’ customers.

Permitted disclosures include, for instance, providing information to unrelated third parties who need to know that information to assist us in providing services to you (such as the custodian of your assets). In all such situations, we stress the confidential nature of the information being shared.

Restrictions on Divulging Client Information
We do not — and will not — sell information about our current or former clients or their accounts to third parties. Neither will Advocate share such information with others except as noted above.

In addition, Advocate will restrict access to clients’ non-personal financial information to those employees of Advocate who need to know such information in order to provide services to you.

Protecting Client Information
We retain records relating to the professional services that we provide so that we are better able to assist you with your professional needs. In order to guard your non-public personal information, we maintain physical, electronic, and procedural safeguards that comply with our professional standards.

If you have any questions about our privacy policy, please contact us at 312-578-8300 or via the contact form.