At Strategic Financial, we are committed to protecting our clients’ personal and financial information. Establishing, and adhering to, an effective privacy policy is an important part of this commitment.

In the course of providing our financial products and services, it is necessary for us to collect and maintain certain nonpublic personal and financial information. Listed below are details regarding our commitment to protecting the privacy of this information, including the types of information we collect about you, how we use and share that information, and how you can instruct us to limit certain types of information sharing.

This privacy policy applies to all of our customers, both past and present. We may change our policy or this notice from time to time. If we do, we will notify you as required by applicable law.

Safeguarding your privacy is our priority

We strive to safeguard your personal information. Some of the measures we rely on to do this include:

• Limiting employee access to sensitive information
• Requiring service providers who do business with us to comply with privacy laws
• Providing privacy training to our employees

What types of personal information we collect

"Personal information" means information that identifies you personally. We may collect the following types of personal information about you.

• Information provided by you. Information you provide on applications, questionnaires and other forms when you purchase one of our financial products or services or promotions, or through discussions we have with you. The information we collect may include your name, address, phone number, email address, Social Security number, and date of birth, as well as details about your interests, investments and investment experience.

• Transaction and experience information. Once you have signed on with us to receive one or more of our products and/or services, we collect and maintain personal information about the products or services you have selected and your transactions with us. This information allows us to administer your customer account and provide the services you have requested.

• Information about you from third-party information providers. We may collect information about you from information services and consumer reporting agencies to verify your identity, employment or creditworthiness, or to better understand your financial needs.

Sharing and using information

We may share and/or use any of the personal information described above with affiliates and nonaffiliated third parties as stated in this policy notice. In addition, we may use information that does not personally identify you. We may use this non-personal information even if you ask us to limit disclosure of your personal information, as described in "Your Privacy Choices" below.

Sharing Information with Affiliates. Our affiliates to whom we may disclose personal information about you engage in several different businesses, including tax planning, corporate structuring, mortgage services, financial planning and investment services. Our ability to share information with our affiliates helps us to more easily provide you with quality products and services to meet your financial needs and goals. For a list of our affiliates with whom we may share information, see below under "Who is covered by this policy. "

Sharing Information with Nonaffiliated Third Parties. We may disclose personal information about you as permitted by law to financial services providers, such as mortgage lenders, consumer finance, securities and insurance, and/or non-financial companies, such as companies engaged in direct marketing and the selling of consumer products and services. If you select Choice #1 under "Your Privacy Choices below"
we will not disclose personal information about you as described above in "What types of personal information we collect" to nonaffiliated third parties except as required or permitted by law. For example, we may still share personal information about you with firms that assist in marketing our products or services, or with other financial companies that have joint marketing agreements with us, or as is necessary to process and service your customer account or a financial product and/or service requested by you, to protect against fraud, and to protect the security or confidentiality of our records, or as otherwise required by law. Also, if you have authorized us to share information in connection with a particular product and/or service, we will continue to share information about you in connection with that product and/or service.

Your Privacy Choices

The law allows you to opt-out of our sharing your personal information in certain circumstances. This section describes your privacy choices. Regardless of your privacy choices, we will continue to safeguard your personal information.

We offer the following three choices about sharing your personal information. To indicate your privacy choices, you can check the appropriate box or boxes or call us toll free at the number below.

Your choice will be applied to you as an individual and will automatically be extended to all of your customer accounts with any Strategic Financial company.

• Choice #1. Limit Disclosure to Nonaffiliated Third Parties. As described in this notice, we will limit the personal information about you that we disclose to nonaffiliated third parties if you select this Choice #1.
  
  
• Choice #2. Limit Sharing with Strategic Financial Affiliates. The law allows us to share with our affiliates information about our transactions or experiences with you, such as your transaction history, and also your name, address and telephone number. Unless otherwise permitted by law, we will not share with our affiliates other information that you provide to us or that we obtain from third parties if you select this Choice #2.
  
  
• Choice #3. Limit Marketing by Strategic Financial Affiliates. If you select this Choice #3, we will limit our affiliates from marketing their services and products to you if you do not have a customer account or business relationship with them.

TO RECORD OR UPDATE YOUR PRIVACY CHOICES, CALL OUR TOLL-FREE CUSTOMER SERVICE NUMBER AT 1-888-845-0827, AND SELECT “PRIVACY CHOICES” FROM THE MENU OF OPTIONS, OR EMAIL US AT PRIVACYPOLICY@SFSTAXES.COM.

You may make your privacy choice(s) at any time. However, if we do not hear from you, we may share some of your information with our affiliates or third parties with whom we have contracts to provide products and services, as permitted by law. We will process any elections you make above within 30-45 days from receipt of your request.

You do not need to contact us unless you want to make one of the privacy choices listed above.

Additional Rights under State Laws

You may have other privacy protections under applicable state laws. For example, if your address is in Vermont or California, we will automatically limit information sharing or disclosure of information about you, except as otherwise permitted by law.

We will automatically treat accounts with Vermont billing addresses as if you filled in Box 1 and Box 2 on the Privacy Choices Form. And if we disclose information about you to nonaffiliated third parties with whom we have joint marketing agreements, we will only disclose your name, address, other contact information, and information about our transactions or experiences with you.

Ensuring Accuracy of Information

We are committed to keeping accurate, up-to-date records to help ensure the integrity of the information we maintain about you. If you identify an inaccuracy in this information, or if you need to make a change to it, please contact us promptly by calling 1-888-845-0827 or emailing via privacypolicy@sfstaxes.com. If you have any questions or concerns, please contact us by email at privacypolicy@sfstaxes.com or call us at 1-888-845-0827.

Who is covered by this policy

The Strategic Financial group includes the following companies controlled by Strategic Financial Holdings, LLC: Strategic Financial Companies, LLC, Strategic Financial Wealth, LLC, and Strategic Financial Mortgage, LLC. This Privacy Notice is applicable to customers of each of the Strategic Financial companies listed above, and any privacy choices selected shall automatically apply to each of these companies.

Policy Effective Date: September 2008