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We may collect non-public, sometimes personal, information about ourclients and parties who engage our firm to participate in certainsecurities transactions from the following sources:
We do not disclose any non-public information about you to anyone,except as permitted or required by law. We restrict access tonon-public personal information about you to those employees,affiliated persons and registered representatives who need to haveaccess to such information in order to provide securities-relatedservices to you. We maintain physical, electronic, and proceduralsafeguards that comply with federal standards to guard yournon-public personal information. If you have any questions regardingthis policy, please contact AAC.
Under Section 326 of the USA PATRIOT Act, AAC is required to verifythe identity of its clients, and we may utilize the services ofoutside vendors to assist us with this government-mandatedrequirement. To help the government fight the funding of terrorismand money laundering activities, federal law requires AAC to obtain,verify and record information that identifies each person who opensan account. For purposes of CIP, the regulation defines “account”as a formal relationship with a broker-dealer established to effecttransactions in securities. Financial Crimes Enforcement Network(“FinCEN”) and the CDD rules requires AAC to identify and verifythe identity of beneficial owners of its legal entity clients.