JOINT PRIVACY PROTECTION POLICY

I. Confidentiality and Security

Together with our participating correspondent firms, we at Cales Investments, Inc. take our role in protecting the private personal and financial information that we have obtained about you with the utmost sincerity. We restrict access to nonpublic information about you to those employees who need to know that information to provide products or services to you and in the maintenance and service of your account. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information. Whether you are a current customer or a former customer you have our assurance that your information will be duly protected.

II. Categories of information we collect

As accounts introduced to Cales Investments, Inc. by independent broker dealers, nonpublic information about you is obtained by your broker/dealer and Cales from the following sources:

• Information we receive from you on applications or other forms,
• Information about your transactions with us, our affiliates, or others,
• Information provided by firms for which we provide other services; and
• Information we receive from a consumer reporting agency

III. Disclosures of Nonpublic Information

Neither Cales nor your broker dealer discloses any nonpublic information about our customers or former customers to anyone, except as permitted by law. Disclosure may be necessary in several instances for example, to insure that your account receives adequate service or in direct response to a regulatory request.

We will not share information about you to unaffiliated third parties, such as security broker dealers, unless the receiver enters into an agreement that they will also maintain your private information with the utmost care and will not utilize the information other than for the purpose fro which it was disclosed. The same standard will be applied to all contractual arrangements wherein your information may be shared, such as computer service providers and statement vendors.

We do not anticipate a change in our disclosure practices. However, in the event that privacy policy, as outlined above, should change you will be notified as to the type of disclosure that will be made and given an opportunity to opt out of said disclosure. Should you request that e disclose information to other parties, such as your accountant; we will do so only with your consent.

IV. Questions regarding the Privacy Policy

A copy of our current privacy policy will be sent to you at the time the account is established and annually thereafter. If you would like additional copies of this notice or if you have questions pertaining to our policy please contact your broker dealer for further information.