| OUR CONTINUING PRIVACY
COMMITMENT TO YOU
As you may be aware, recently enacted federal privacy laws
require that we explain to you how we handle "nonpublic personal
information." This is information that in the course of our
relationship with you, we receive or develop about you. It
includes (1) information you provide to us orally or on applications
or other forms, and (2) information we develop about you in
the course of providing our services to you, such as the amount
and type of your assets that we manage and transactions we
place on your behalf, and (3) technical information we develop
and gather through your access to our website.
As a general rule, we do not disclose this private information
to others. As you might imagine, however, we rely on certain
third parties for services that are necessary to enable us
to provide our [investment] services to you. These may include
our attorneys, auditors, prime brokers, and custodians who,
in the ordinary course of providing their services to us,
may require access to information containing your nonpublic
personal information. In addition, we may disclose your nonpublic
personal information to others with your consent, where required
by law or judicial process (such as a court order), or otherwise
to the extent permitted under the federal privacy laws.
We also restrict access to your nonpublic personal information
among our own personnel. Only those who need the information
in order to help us provide [investment advisory] services
to you have access. It is our policy that, where we are not
comfortable a service provider is already bound by duties
of confidentiality (e.g., attorneys and auditors), we will
require contractual assurances that they will maintain the
confidentiality of any of your information they obtain. We
also maintain [physical, electronic, and procedural] safeguards
to guard your nonpublic personal information.
If you have any questions about our practices with respect
to your nonpublic personal information, you may contact us
at the following:
Mr. Frank Marinaro
Emery & Howard Portfolio Management
577 Airport Blvd., Suite 610
Burlingame, CA 94010
(650) 579-7100
fmarinaro@emeryandhoward.com
http://www.emeryandhoward.com
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