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Privacy Policy

Dear Client:

ADM Investor Services ("ADMIS") and its affiliated broker Stewart-Peterson Group, Inc., (hereafter jointly called the “Companies”) are committed to protecting the privacy, accuracy and reliability of any personal information you choose to provide and to safeguarding such information from loss, misuse, unauthorized access, disclosure and alteration. This privacy policy statement is provided to you jointly on behalf of the Companies and addresses the Companies' data collection, use and disclosure practices. This privacy policy may change from time to time and you will receive written notification of any such changes.

Personal Information the Companies Collect and Why
The reason the Companies collect information is to create and foster ongoing customer relationships. In the normal course of this process, the Companies obtain and retain non-public (personal) information about you, which is transmitted to us directly by you. This information includes your name, address, tax identification number, approximate age and investment experience and other similar information. In addition, the Companies may obtain information about you from the Companies’ affiliates, credit reporting services, regulatory information providers and similar entities. The Companies limit such information to such facts as are necessary to offer accurate and superior service in the normal course of business as it relates to your account carried at ADMIS.

Use of Personal Information
The Companies use your personal information for three general purposes:

i. First, the Companies use the information to activate an account for you and/or to make changes or additions to information previously provided to us to open an account for you.

ii. Second the Companies may use it to give you (and only you) online access to our account information and the Companies’ proprietary information in a secured environment.

iii. Third, the Companies use the information in the normal course of business to transmit account activity statements and related documents to you relating to activity in your account with the Companies.

Disclosure of Personal Information
The Companies take very seriously their responsibilities to keep your personal information
private. The Companies will not disclose non-public personal information about our customers
unless as permitted by law and in the following instances:

i. n processing or servicing of products or services offered by the Companies that have been consented to, requested by or authorized by the customer.

ii. The Companies may share your personal information as is necessary to conduct credit history checks, process or collect payments, or to service your account.

iii. The Companies may be required to disclose personal information by law or legal process for a variety of reasons, including protecting and defending the rights or property of the Companies and periodically reporting trading gains or losses as required by the Internal Revenue Service. The Companies may also be required to disclose personal information to the regulatory bodies whose jurisdiction we are subject to.

iv. Except under the circumstances described above, the Companies will not disclose any of your personal information to unaffiliated third parties, unless specifically authorized by you in writing to do so.

The confidentiality and conditions of this agreement will continue to be maintained even when you cease to do business with the Companies.

How the Companies Protect Personal Information
The Companies take reasonable measures to protect your personal information from unauthorized access through the use of physical security, and use and access policies for employees. The Companies safeguard customer information from unauthorized access by limiting the number of employees permitted to access such information through personalized staff passwords, and by having in place a process for disciplinary action where appropriate.

Information Sharing with Affiliates of the Companies

Although by law we are permitted to share information with our affiliates and subsidiaries related to our transactions and experiences with you, it is the policy of the Companies not to do so without your specific authorization. Accordingly, the Companies will not share any personal information either provided by you or obtained from third parties, unless authorized by you in writing to do so.

Accuracy of Personal Information
On an ongoing basis the Companies evaluate our efforts to protect your personal information and ensure its accuracy. Should you identify any inaccuracy in the personal information included in any communication you receive from the Companies, please notify the ADMIS Compliance Department immediately at 1/800/243-2649. The Companies will take reasonable steps to ensure it is corrected on a timely basis.

Effective March 15, 2002