Physical security of Non-public Personal Information

It is the policy of the Firm to respect the privacy of its clients and to protect the security and confidentiality of their nonpublic personal information. Firm personnel may not disclose to an affiliated or nonaffiliated third party any nonpublic personal information unless required or authorized by law and the rules promulgated by The Florida Bar regarding client confidentiality and then only to the extent necessary to process a transaction or to provide services requested or authorized by the client. Nonpublic personal information may only be disclosed as provided by the Gramm-Leach-Bliley Act (“GLBA”) in 15 USC 6802(e) provided, provided such disclosure is also in compliance with any rules promulgated by The Florida Bar regarding client confidentiality.