Privacy Policy

In accordance with the Gramm-Leach-Bliley Act enacted by the U.S. Congress, we are providing you with this statement of our privacy policy (our “Privacy Policy”) in relation to information that you provide to us. Our relationship with you as your investment manager is of a fiduciary nature and we are extremely sensitive to maintaining the confidentiality of the personal information that you provide to us.

Our privacy policy is as follows:

1. We collect personal information about you from information we receive from you on applications or other forms, information from your transactions with us in the normal course of business, information we receive from third parties who, with us, provide services in connection with your account and information we receive from consumer reporting agencies to verify your identity or to open a margin account.
2. We do not sell your personal information, including social security numbers and birthdates, to anyone.
3. Except as permitted by applicable law and except as you may expressly authorize, we do not disclose personally identifiable financial information or any list or description that is derived using any personally identifiable financial information that is not publicly available except as necessary to allow us directly or through nonaffiliated third parties to perform services for you in connection with your accounts, such as completing trades of securities. With your express consent or at your direction we provide non-public personal information to your professional advisers such as your accountants and lawyers as well as to other third parties such as lenders or creditors.
4. We restrict access to your nonpublic personal information, including social security numbers and birthdates, to those employees who need to know that information in order to serve you and properly maintain, administer and service your account. Our employees are prohibited from using your information for their own purposes and are required to maintain the confidentiality of your nonpublic, personal information.
5. As mentioned above we may disclose your nonpublic personal information to unaffiliated third parties (such as Charles Schwab) to assist us in providing services to you that you request or authorize, such as processing your transactions, in executing trades at an exchange, in maintaining and servicing your account, or in providing financial products to you from other financial institutions. In each case, a separate account relationship is established for you personally with those entities. Under the terms of your individual account agreements with such third parties they are, in turn, prohibited from using your nonpublic personal information for their own purposes and are required to maintain the confidentiality of your nonpublic personal information.
6. We may disclose your nonpublic personal information, including social security numbers and birthdates, in response to lawful requests from federal, state or local governmental authorities, and as otherwise permitted or required by law.
7. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information.
8. We take every effort to maintain the currency and accuracy of all your personal information. If there is any inaccuracy, please contact us and we will update our records without delay.
9. This Privacy Policy applies to all current and former customers.
10. This is our Privacy Policy. If our Privacy Policy should change in any way we will give you advance notice.

If you should have any questions or concerns regarding our Privacy Policy, please feel free to contact us to discuss it in greater detail. We appreciate the trust and confidence that you place with us.

Sincerely yours,

CALLAHAN CAPITAL MANAGEMENT