The Firm views protecting its customers' private information as a top priority and the Firm has instituted policies and procedures to ensure that customer information is kept private and secure.BDA does not disclose any nonpublic personal information about its customers or former customers to any nonaffiliated third parties, except as permitted by law. In the course of servicing a client's account, BDA may share some information with its service providers, such as transfer agents, custodians, broker-dealers, accountants, and lawyers. BDA restricts internal access to nonpublic personal information about the client to those associated persons of the Firm who need access to that information in order to provide services to the client. As emphasized above, it has always been and will always be the Firm's policy never to sell information about current or former customers or their accounts to anyone. It is also the Firm's policy not to share information unless required to process a transaction, at the request of a customer or client, or as required by law.