We collect nonpublic information about you from the following sources:

• From you on applications or forms.
• From transactional activity in your account (for example, trading history and balances).
• From statements provided by you of other financial accounts.
• From other sources with your consent (for example, your attorney, CPA or other professional).

We do not disclose any nonpublic personal information about our clients or former clients to anyone, except as required to perform the services you have requested, administer your account with us or as otherwise permitted by law.

We restrict access to nonpublic personal information about you to those of our employees who need to know that information to provide services to you. We maintain physical, electronic and procedural safeguards to guard your nonpublic personal information as set forth in the IMS Physical and Cybersecurity Policies.

Last Updated January 2022