Annual Notice of Privacy Practices

Individuals to Whom Privacy Policies Apply

Adviser's privacy policies apply to any individual (natural person) from whom Adviser obtains nonpublic personal information in connection with the individual receiving a financial product or service. This individual is referred to as a "consumer" under Regulation S-P. Any individual(s) receiving advisory services from Adviser is a consumer for purposes of Regulation S-P. Any individual who has applied for advisory services and in the process provided nonpublic personal information to Adviser would also be considered a consumer under Regulation S-P.

Policy Regarding Use of Nonpublic Personal Information

Adviser treats client information that is considered "nonpublic personal information" under the terms of Regulation S-P as confidential information and may not be disclosed except as follows:

• To other employees in connection with Adviser's business;
• To an affiliate, but the affiliate may only disclose the information to the same extent as Adviser;
• To nonaffiliated third parties with whom Adviser has a contractual agreement or other arrangement by which the nonaffiliated third parties provide services to Adviser that are "necessary to effect, administer, or enforce" the services that are authorized by the client, for example, custodial, brokerage, legal and similar services.

Currently, Adviser has no joint marketing or servicing arrangements with unaffiliated third parties where it shares nonpublic personal information about its individual clients or potential clients, except as necessary to carry out authorized client services. Thus, no employee shall enter into a joint marketing or servicing agreement with a nonaffiliated third party through which nonpublic personal information is shared. Any changes to this prohibition require a revision to these privacy policies and further require Adviser to provide its clients with an opportunity to opt out of the arrangement prior to the release of any nonpublic personal information to a nonaffiliated third party.

Procedures Regarding Use and Treatment of Nonpublic Personal Information

Adviser requires that its employees be aware of and sensitive to their treatment of nonpublic personal information of its clients and potential clients. Adviser prohibits its employees from discussing such information unless necessary as part of their duties and responsibilities to Adviser. Furthermore, Adviser requires that each employee take precautions to avoid storing nonpublic personal information in plain view in public areas of Adviser's facilities, and requires that each employee remove nonpublic personal information from conference rooms, reception areas and other areas where it may be seen by third parties. Particular care should be exercised when nonpublic personal information must be discussed in public places, such as restaurants, elevators, taxicabs, trains, or airplanes, where such information may be overheard. Under no circumstances may nonpublic personal information be shared with any person, including any spouse or other family member, who is not an employee of Adviser and who does not have a reason to know such information.

Adviser routinely reviews its security measures, such as computer storage of nonpublic personal information, to ensure that reasonable steps are taken to safeguard such information.