Normandy Capital Management, LLC
575 Union Blvd, Suite 201
Lakewood, CO 80228

Normandy Capital Management, LLC's (“NCM, LLC”) primary client goal is to protect
your privacy. We share a commitment to protect your privacy and the confidentiality of
your personal and financial information. NCM, LLC will limit how, and with whom, we
share customer information. We do not sell lists of our customers, nor do we disclose
customer information to marketing companies.

NCM, LLC collects only the customer information necessary to consistently deliver
responsive products and services. We collect information that helps serve your financial
needs, provide high standards of customer service and fulfill legal and regulatory
requirements. We may collect nonpublic personal information from sources such as: (a)
Information reported by you on applications or other forms you provide to us and through
personal interviews, (name, social security number, address, assets, etc.); (b) Information
about your transactions with us, our affiliates, or others (account information, payment
history, parties to transactions, etc.); and (c) Upon your consent, information provided by
your professional financial service providers such as accountants, attorneys, employer
plan administrators, mortgage brokers, insurance companies, broker dealers, or others.
NCM, LLC shares nonpublic information solely to service our client accounts, we do not
disclose any nonpublic personal information about our customers or former customers,
except as permitted by law.

NCM, LLC in order to provide the utmost in service, may disclose the information as
described above, regarding customers and/or former customers, as necessary, to
companies to perform certain services, on our behalf or to other financial institutions with
whom we have agreements, or as required by law. Companies with which we share
customer information are required to maintain the confidentiality of that information.
NCM, LLC at times, may disclose nonpublic personal information to affiliated or
nonaffiliated third parties (i.e., your financial service providers). We may share any of
the information that we collect as described above.

Information Safeguarding
NCM, LLC will internally safeguard your nonpublic personal information by restricting
access to only those employees and representatives who provide products or services to
you or those who need access to your information to service your account. In addition,
we will maintain physical, electronic and procedural safeguards that meet federal and/or
state standards to guard your nonpublic personal information.