OUR COMMITMENT TO YOUR PRIVACY

The CitrinGroup wants to be your premier source of investment advisory services. To do that requires us to acquire and maintain your utmost trust and respect. That is one reason why we treat your personal financial information in the strictest confidence, and disclose such information only where it is required or permitted by law.

We are providing you this notice in compliance with the Gramm-Leach-Bliley Act of 1999 and SEC Regulation S-P to inform you of the different types of personal information we collect from you, the manner in which we use such information, and the circumstances under which we may disclose such information. In general, we do not disclose any nonpublic personal information about our customers or former customers to anyone, except as required or permitted by law.

Types of Information We Collect About You

The CitrinGroup collects the following types of personal information about you from the following sources:

a. Information we receive from you on applications or other paper or Web-based forms (such as your name, address, social security number, e-mail address, and banking account information);

b. Information about your financial and investment transactions with us, or with others (such as your account balance, any balance transfers, commodities or securities you have bought or sold);

c. Information we are required to obtain in order to assess your experience investing and trading in investments with increased risk and reward potential (such as your annual income, personal net worth and investment preferences); and

d. Information we receive about you from any consumer reporting and credit agencies (such as your creditworthiness and credit history).

We also collect information about you and your computer when you visit and use our Web site to browse, read, or download information. We automatically collect and track certain technical and routing information about you, such as your home server domain names, type of computer, and type of Web browser in addition to tracking your use of our Web site. We may match this “Click Stream” data with personal information that you provide to us through other means.

We track information about you through the use of “cookies.” Cookies are small data files, typically made up of a string of text and numbers, which assign a unique identifier to you. This information enables your computer to have a “dialogue” with our Web site and permits us to administer our site more efficiently and to provide a more tailored and user-friendly service to you. We use two types of cookies. “Persistent” cookies are stored on your hard drive until deleted or until an expiration date. We use persistent cookies to assign an identifier number to your computer that will give you access to our site and to store graphics files that record how our site will be displayed on your computer. “Session” cookies are stored temporarily on your computer and are deleted when you log off the computer, exit the browser or if you are inactive on our site for a specified period. We use session cookies to permit you to access and navigate our site without repeated log-ins and to personalize our site according to your preferences. Our advertisers also place cookies on your hard drive that notify them automatically when you click on one of their advertisements.

You may disable cookies by changing your Internet preferences on your computer. In such case, you will have to re-log in each time you enter the sites to take advantage of the sites’ full capabilities. Please note that our Web sites contain links to other Web sites. We are not responsible for the privacy practices or the content of other Web sites and are not responsible for any dealings with such Web sites. Please contact these companies directly if you have any questions about their collection or use of information about you.

We do not disclose any of the above nonpublic personal information about you to anyone, except as required or permitted by law.

How We Use and When We May Disclose Information About You

In order to better serve you, The CitrinGroup may engage non-affiliated companies to support a financial product or service we provide to you, or to maintain and protect the security of your accounts with us. These companies may not be affiliates of The CitrinGroup, and may be transfer agents, clearinghouses, accounting and reporting firms, systems operations firms, and other companies that perform support services for The CitrinGroup. They may also be companies in related businesses that support the product and service offerings of The CitrinGroup, for example, insurance companies, mutual funds, or tax, trust and estate planners, or companies that market our products and services.

We use these companies only to administer, process, service and enforce transactions authorized or requested by you, and to provide support services to The CitrinGroup. In all cases, our contract with these companies prohibits them from disclosing or using the information other than to carry out the purposes described above. Our contract with them also requires them to maintain strict confidentiality of your information.

We may also share some or all of your personal financial information as required to law enforcement and regulatory agencies, and as permitted with your legal representatives, trustees or other fiduciaries.

Confidentiality and Security of Your Information

We are required by federal law to adopt and maintain policies and procedures that are designed to protect your personal information, to insure the confidentiality of your information, and to protect it against unauthorized access or anticipated threats to its security or integrity. At The CitrinGroup, we limit access and use of your personal information strictly to those employees who need to know such information in order to serve to you, and to the circumstances described above.

While we reserve the right to change this policy at any time, we will notify you of any such changes. Please keep this privacy notice for your records.

THE CITRINGROUP – WE VALUE YOUR PRIVACY