PRIVACY POLICY

At Hehmeyer Capital Management LLC (“HCM”), maintaining client trust and confidence is a high priority. We understand that you are concerned with how we treat nonpublic personal information (“Client Information”) that we obtain from you, or from other sources about you, in the course of providing you with our products and services. For this reason, we want you to understand how we work to protect your privacy when we collect and use your Client Information. We also want you to understand and be aware of the steps we take to safeguard your Client Information.

SECURITY PROCEDURES:

We restrict access to Client Information about you to the following:
• Employees and affiliates who need to know that information in order to provide the products and services you receive from us.

• Third parties whose access to such information is permitted or required by law and who need to know that information in order to assist us in providing you with the products and services you receive from us.

To protect the security of your Client Information, we maintain physical, electronic, and procedural safeguards to guard the information we collect about you. While HCM has written policies and procedures with respect to safeguarding your Client Information, it is possible (although highly unlikely) that a third party may be able to gain unauthorized access to such information by “hacking” into HCM’s system or otherwise.

INFORMATION WE COLLECT:

In providing you with financial products and services, HCM may collect the following types of Client Information:
• Information from your account applications and other forms (for example, your name, address, social security number, income, investment experience or other financial information).

• Information about your transactions with us, our affiliates, or other related parties (this information may include, but is not limited to, your trading history, your history of meeting margin calls, and your use of various products and services).

We may also collect information about your creditworthiness, credit history, and other information about you from consumer reporting agencies, our affiliates, or providers of other demographic information, such as your investment and trading preferences.

We may also collect information about you obtained in connection with our efforts to protect against fraud or unauthorized use of your account.

PARTIES TO WHICH WE MAY DISCLOSE:

We may disclose the Client Information listed above to affiliates who assist us in providing certain products and services.

We may also disclose your Client Information to nonaffiliated third parties to process, service or administer transaction you authorized or initiated, maintain accounts, respond to court orders and legal investigations or as permitted by law.