Privacy Policy

FACTOR CAPITAL MANAGEMENT LLC
PRIVACY NOTICE
February 22, 2011

Commitment to Its Customers

Factor Capital Management, LLC ("Factor") recognizes and respects the privacy expectation of each of its customers.  Factor believes that the confidentiality and protection of its customers' non-public personal information is one of its fundamental responsibilities.  This means, most importantly, that Factor does not sell customers' non-public personal information to any third parties.  Factor uses its customers' non-public personal information primarily to complete financial transactions that its customers request or to make its customers aware of other financial products and services offered by a Factor affiliated company.

Information Factor Collects About Its Customers

Factor collects non-public personal information about its customers from the following sources:
- Account Applications and Other Forms, which may include a customer's name and address, date of birth, social security number or tax identification number, total assets, income, employment history and accounts at other institutions;
- Account History, which may include information about the transactions and balances in accounts or products with Factor;
- Correspondence, which may include written, telephonic or electronic communications.
- Information for verification purposes (such as verification of identity, credit reports, etc.)

How Factor Handles Its Customers' Personal Information

As emphasized above, Factor does not sell non-public personal information about current or former customers to third parties.  Below are the details of circumstances in which Factor may disclose non-public personal information to third parties:

- Factor may provide non-public personal information to non-affiliated service providers involved in servicing and administering products and services for or on Factor's behalf (such as accountants, compliance consultants, legal advisors, broker-dealers, introducing brokers, futures commissions merchants, investment companies, investment advisers, commodity trading advisors, commodity pool operators, administrators and custodians). In all such cases, Factor will provide the third party with only the information necessary to carry out its assigned responsibilities and only for that purpose.  In addition, Factor requires these third parties to treat Factor customers' non-public information with the same high degree of confidentiality that Factor does.

- In order to complete certain transactions or account changes that a customer directs, it may be necessary to provide certain non-public personal information about that customer to companies, individuals, or groups that are not affiliated with Factor.  For example, if a customer asks Factor to transfer assets from another financial institution, Factor will need to provide certain non-public personal information about that customer to the company to complete the transaction.

- Factor will release non-public information about customers if directed by that customer to do so or if Factor is authorized by law to do so. Factor may release such information to courts and other parties related to a subpoena or other court, government or self regulatory organization order or process.

- Factor may release non-public personal information to regulators (including self regulatory organizations) or governmental entities that have made a reasonable request for such information.

- Factor may release non-public personal information to certain governmental entities and others to prevent money laundering.

- In order to alert a customer to other financial products and services that a Factor affiliated company offers, Factor may share non-public personal information it has about that customer with a Factor affiliated company.

How Factor Safeguards Its Customers' Personal Information

Factor restricts access to information about customers only to those employees who require that information to provide financial products and services to that customer.  Factor maintains physical, electronic, and procedural safeguards that comply with federal standards to guard its customers' non-public personal information.