In opening and servicing customer accounts, Joseph Gunnar & Co., LLC (JGUN) needs to collect certain kinds of personal information - identifying information such as your name, address, telephone number, e-mail address, social security number, application information such as information about your assets, income, investment goals, and risk tolerance and transactional information such as account activity information. JGUN will use such personal information only in ways that are in accord with the purposes for which it was originally requested. For example, we will use the information you provide us to process your requests and transactions, to provide you with additional information about products and services, or to evaluate your financial needs. We may share such information with our clearing agent, RBC Correspondent Services. We limit the collection and use of personal information to that which is necessary to administer our business and to deliver superior service to you. JGUN will not share personal information with others except as stated in this policy, unless we give you additional notice or ask for your permission. JGUN reserves the right to disclose or report the personal information in certain circumstances: (1) to our clearing firm, as JGUN deems necessary or appropriate, to handle, process and clear transactions in accounts; (2) where we believe in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities; (3) to perform necessary credit checks or collect or report debts owed to us; (4) to protect our rights or property; or (5) upon reasonable request by a mutual fund or other appropriate entity relating to other investments in your account. JGUN does not sell its customers' or potential customers' personal information. JGUN will protect the confidentiality of any personal information you share with us. Our corporate policies require that employees with access to customer personal information may not use or disclose the information except for business use described above. All employees are required to safeguard such information. JGUN strives to improve its efforts to protect personal information and makes every effort to keep your personal information accurate and up to date. If you identify any error in your personal information or need to make a change to that information, please contact us and we will promptly update our records. If you have any questions or concerns, please contact Joseph Gunnar & Co.'s Chief Compliance Officer at 212-440-9645.