Privacy Policy

How and Why We Collect Personal Information

EMM may collect personal information from clients in order to offer or provide clients with products or services, process transactions on their behalf and comply with legal and regulatory requirements. Information may be collected from any of the following sources:

• EMM collects information from clients on applications or other forms such as W-9's or investor questionnaires. This information may include items such as a client's name, address, e-mail address, social security number, birth date, annual income, net worth, marital status, investment goals and investment risk tolerance. If a client indicates that he or she has a spouse or partner, his/her personal and financial account information may also be requested.
• If a client obtains advice or services from EMM, EMM keeps records relating to items such as the client's ownership of certain types of accounts or the client's securities positions. This enables EMM to provide the client with a history of the client's transactions with EMM and service the account.
• If a person visits EMM's web site, EMM may use a feature commonly known as a "cookie" to track certain technical information such as the amount of time the person spends on the site or which areas of the site the person visits. EMM uses this information to improve the functionality of its web site.
• EMM may also obtain information from a consumer reporting agency or a self-regulatory organization or other trade organization.

Disclosure of Personal Information

EMM does not disclose nonpublic personal information about its current or former clients to third parties except as permitted by law or by written consent of such clients. In the normal course of servicing clients, information EMM collects may be shared as follows:

• EMM will reveal or share a client's personal information where the law requires it, such as for tax reporting purposes, "know your customer" regulations, or pursuant to a request from a government agency or a court order.
• EMM may reveal or share a client's personal information with its affiliates as permitted by law.
• EMM may reveal or share a client's personal information with unaffiliated service providers such as non-EMM managed investment funds, broker-dealers, custodians and transfer agents in connection with processing transactions for a client's account. A client's personal information may also be provided to attorneys, accountants or auditors in order to enable EMM to provide requested services to the client and to comply with legal and regulatory requirements.

Access to personal information

EMM restricts access to nonpublic personal information except to the extent necessary or appropriate to provide products or services. EMM maintains physical, electronic and procedural safeguards to guard nonpublic personal information.