As a financial services firm, much of the information we collect about our clients is
subject to the privacy provisions of the Gramm-Leach-Bliley Act (GLBA) and therefore not
subject to the California Consumer Privacy Act (CCPA), as amended by the California
Privacy Rights Act (CPRA). This GLBA information includes any information:(i) provided to
us by a client in order to obtain a financial service or engage in a transaction (e.g.
name, address, income, Social Security number, or other information on an application);
(ii) obtained about a client from a transaction involving financial products or services
(e.g. account numbers, transactions, positions or other information), and (iii) obtained
in connection with providing a client a financial product or service. Because such GLBA
information is not subject to the CCPA, it will typically not be included in any response
to an information request and is not subject to the deletion rights under CCPA.
