Privacy Policy

Strubel Investment Management, LLC (“SIM”) is committed to maintaining the confidentiality, integrity and security of personal information about our current and prospective customers. We understand that privacy is an important issue for you, and we want you to understand how we work to protect your privacy when we collect information about you.

How We Obtain Personal Information

In providing you with financial products and services, or information about such products and services, SIM may collect public and non-public personal information about you from the following sources: your account agreements and other related documents and forms (for example, name, address, social security number, birth date and financial information) transactions with SIM outside entities, including credit reporting agencies, to obtain information (such as verification of identity, credit-worthiness, credit history, purchasing and investment preferences).

Sharing Information

SIM, its employees and its affiliates may share all the information collected within SIM. Examples of this information may include identification information and transaction and experience information.

Safeguarding Privacy

SIM recognizes the need to prevent unauthorized access to the information we collect, including information held in electronic format. SIM authorizes access to your nonpublic personal information only to personnel who need that information to serve you. We maintain physical, electronic, and procedural safeguards regarding your nonpublic personal information to ensure that we comply with our own policy, industry practices, and federal and state regulations. If you decide to close your account(s) we will adhere to the privacy policies and practices as described in this notice. SIM regularly provides notices to its customers regarding its privacy policy. SIM reserves the right to change this policy, and to apply changes to information previously collected, as permitted by law. If there is any change to this policy, SIM will provide its customers with a revised privacy notice.

Last Updated: September 2009

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