Privacy Policy

PRIVACY RULE (REGULATION S-P)

Regulation S-P (Privacy Rule) aims to protect sensitive client data by restricting a financial institution's ability to disclose nonpublic personal information about consumers.

The Privacy Rule requires a financial institution to adopt a Privacy Policy and send consumers the firm's Privacy Notice.

PRIVACY POLICY

In the normal course of our business we collect nonpublic personal information about clients (this term defined to be inclusive of prospective clients) from information received from the client on applications and other forms, and from information about client transactions with us. We restrict access to nonpublic personal information to employees. Employees are to treat this information as confidential.

We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law. As permitted by law, we may disclose personal information to companies that effect, administer, or enforce a transaction that is requested or authorized by the consumer.

We will provide customers with an initial and annual notice of our privacy policies.

If our policy changes, and we begin to disclose nonpublic personal information outside the exception, we will provide customers with an opt out right and allow a reasonable time to opt out.

We have established safeguards to protect the security and confidentiality of customer records and information.

Physical Security

• Employees are to shred discarded paper records.
• Employees are to erase/destroy electronic media before discarding.
• The computer is secure and restricted to employee access only.
• The office is secure and restricted from access by outside parties when employees are not present.

Administrative Security

• Daniel Sheldon Jewell is the designated person responsible for monitoring internal access to customer records and information and determining who has access rights to covered information.
• The designated person will periodically identify and assess the risks that may threaten protected information and adjust procedures to account for changes in technology, the sensitivity of the protected information, and internal or external threats to information security.
• The designated person shall train employees in records safeguarding and records disposal.

Technical Safeguards

• All employees will enter into a confidentiality agreement upon employment.
• Employees shall take other reasonable steps in protecting customer records as may be necessary from time to time.

Safeguards Rule Applicable to State RIAs

We have adopted an information security program to include security procedures and protection against system failures. (See separate document Business Continuity Plan.)

• JEWELL, DANIEL SHELDON will notify customers promptly if their nonpublic personal information is subject to unauthorized access.
• Daniel Sheldon Jewell is to coordinate the Business Continuity Plan.
• JEWELL, DANIEL SHELDON conducts background checks on potential employees with access to customer information.
• Employees sign confidentiality agreements with JEWELL, DANIEL SHELDON.
• We train employees on procedures and implement controls for access to information.

Note that any records that must be maintained for recordkeeping purposes will be maintained for the required length of time. Discarded paper records and electronic media will only be disposed of after ensuring that appropriate records are maintained for the required length of time.

PRIVACY BREACH

In the event that JEWELL, DANIEL SHELDON learns that computers or sensitive data is lost or stolen, we will promptly take the following steps:

• Notify the local police
• Notify the brokerage custodian to be on the alert for unusual activity in the account
• Initiate our internal review of accounts and continue monitoring for a reasonable period
• Notify clients in writing of the steps we have taken and caution them to be alert for unusual activity