As required under applicable federal law, this is a notice to inform you of the privacy policies of Brown Associates, Inc. and its owners, officers, employees, et al (collectively referred to herein as the “Firm”). 

           The Firm does not disclose non-public information about its clients or former clients to third parties other than as set forth below. 

           As you know, the Firm obtains information about you in connection with the investment services provided by the Firm to you.  This information may include your name, address, social security number, tax identification number, net worth, total assets, income and other financial information necessary to determine required suitability standards (as well as financial sophistication).  This information may be obtained through discussions, documentation (such as account forms, W-9 forms, etc.) and in the course of the Firm providing services to you.

           The Firm may use this information to provide investment services to you, which can include the opening of accounts and other actions necessary to effect your transactions.  In connection with providing you with such services, the Firm may provide your personal information to its attorneys, accountants and/or auditors.  The Firm also provides such information to its clearing firm and, when and if requested, to government authorities making requests for such information.  It should be noted that should the Firm be asked to disclosure personal information about you, the Firm will require all such persons making requests to protect the confidentiality of your personal information and to use such information only for the purposes for which it was disclosed to them.

           Except as noted above, the Firm does not, and will not, provide non-public personal information about you to outside firms, organizations, groups or individuals.  The Firm restricts access to non-public personal information about you to its employees who need to know such information to provide administrative services to you.  The Firm will maintain such safeguards that comply with federal standards to protect your non–public personal information.