INFORMATION WE COLLECT AND SHARE

We collect a variety of nonpublic personal information about you, which may include:

• Information we receive from you, as provided, for example, on applications or other forms.
• Information about your transactions with us, our affiliates, and others. (Our affiliates include financial service providers such as investment managers, securities broker dealers, and transfer agents.)
• Other information we receive from affiliates and nonaffiliated third parties.

We disclose this information only as required or permitted by law. For example, we may share information with affiliates or nonaffiliated third parties that provide services to us, in order to process your transactions and service your accounts. We may also share information with those who perform marketing services on our behalf, or financial institutions with whom we have joint marketing agreements that provide for the confidentiality and security of investor information. When necessary, we also disclose investor information to regulatory agencies, law enforcement agencies, courts, or parties to lawsuits.

CONFIDENTIALITY AND SECURITY OF NONPUBLIC PERSONAL INFORMATION

We are careful to restrict access to your nonpublic personal information. Our employees, and in certain cases nonaffiliated third parties, have limited access to investor information based on their responsibilities. This access enables them to assist you in completing transactions, offer you additional financial services, and resolve any investor service issues that may arise. All employees are instructed to follow the confidentiality guidelines provided in our Code of Conduct, which is strictly enforced. We maintain physical, electronic, and procedural safeguards that comply with federal standards to safeguard nonpublic personal information.

NOTICE TO CALIFORNIA USERS REQUIRED BY STATE LAW:

LRG retains information received through this website, including information you give us to open an account or purchase a product or service from us, information you give to us in inquiries and other communications, and records of any transactions you perform. We share this information with affiliated and nonaffiliated parties only as necessary to process and service your transactions with us, or as required by law. Such parties may include those who provide services to us in connection with your accounts or transactions, or who are involved in providing you the services you request. In certain instances they might include a purchaser or potential purchaser of an account. LRG shares information with government agencies and law enforcement as necessary.

PROTECTION OF SOCIAL SECURITY NUMBERS

Like all financial services companies, LRG collects a variety of information about individuals, including but not limited to our investors and employees. In many cases that information includes individuals’ Social Security numbers. We use records of Social Security numbers for many purposes, especially to comply with federal and state laws.

Our policy is (i) to comply with all laws restricting the use and disclosure of Social Security numbers, (ii) to protect the confidentiality of Social Security numbers, (iii) to prohibit the unlawful disclosure of Social Security numbers, and (iv) to limit access to Social Security numbers to our employees, and in certain cases to nonaffiliated parties that provide services to us, based on their responsibilities. To safeguard Social Security numbers, we maintain physical, electronic, and procedural safeguards that are designed to comply with applicable legal standards. Our employees are prohibited from disclosing Social Security numbers for unauthorized purposes.