INFORMATION ABOUT PRIVACY AND CERTAIN INFORMATION SHARING
We collect nonpublic, personal information about our clients from the following sources:
Applications (such as client agreements and subscription documents) and other forms,
The information we collect can include name, address, social security number, assets, income and investment objectives.
Our internal data security policies restrict access to nonpublic, personal information to authorized employees. We maintain physical, electronic and procedural safeguards to guard nonpublic, personal information. Employees who violate our data security policies are subject to disciplinary action, up to and including termination.
We may be required to disclose information about you to the following types of third parties:
If you have asked us to work with another investment adviser, securities broker or financial institution, we may disclose your non-public personal and financial information to any of them, as well as to their service providers, legal representatives.
We also may disclose your non-public personal and financial information to any person acting in a fiduciary or representative capacity on your behalf (such as a trustee of a grantor trust or IRA custodian.)
We also use custodians, mailing houses and other third-party businesses to manage your account and provide services to you. We may disclose your personal and financial information to these other businesses in order to better serve you.
We also may disclose your non-public personal information to non-affiliated third parties as permitted or required by law. For example, we may disclose to law enforcement agencies or computer security consultants for the purpose of protecting against fraud and unauthorized transactions or in order to maintain the confidentiality of our records. We may also disclose your non-public personal information to our attorneys and accountants.
On occasion, we may be required to provide information about you and your transactions to governmental agencies, self-regulatory organizations, industry associations and similar bodies in order to fulfill legal and regulatory requirements. In addition, federal and state laws give people involved in lawsuits and other legal proceedings the right under certain circumstances to obtain information from us, including your personal and financial information. We will comply with these laws to the extent that we are required to do so.
On all occasions when it is necessary for BLCC to share your personal information with non-affiliated companies, BLCC will require that such information only be used for the limited purpose for which it is shared and will advise these companies not to further share such information with others except to fulfill that limited purpose.
We will not sell your personal and financial information to any outside third party. In particular, we do not sell or otherwise disclose our customer lists to unrelated businesses that may try to sell you products and/or services.
BLCC takes its responsibility to protect the privacy and confidentiality of clients' information very seriously. If we change our policies to permit BLCC or our affiliates to share additional information that we collect and/or maintain about you, or to permit disclosures to additional types of parties, you will be notified in advance, and, if required by law, will be given the opportunity to opt out of such additional disclosure and to direct BLCC not to share such information with such parties.