Sumnicht & Associates, LLC Privacy Notice

Sumnicht & Associates, LLC (referred to as "Sumnicht"), maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients' nonpublic personal information ("information"). Through this policy and its underlying procedures, Sumnicht attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.

It is the policy of Sumnicht to restrict access to all current and former clients' information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services to the client. Sumnicht may disclose the client's information if Sumnicht is: (1) previously authorized to disclose the information to individuals and/or entities not affiliated with Sumnicht, including, but not limited to, the client's other professional advisers and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. The disclosure of information contained in any document completed by the client for processing and/or transmittal by Sumnicht in order to facilitate the commencement/continuation/termination of a business relationship between the client and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, insurance company, outsourced investment accounting and aggregation services, etc.), including information contained in any document completed and/or executed by the client for Sumnicht (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider.

Sumnicht permits only authorized employees and affiliates who have signed a copy of Sumnicht's confidentiality agreement, which includes the Privacy Notice, to have access to client information. Employees violating Sumnicht's Privacy Policy will be subject to Sumnicht's disciplinary process.

From time to time, Sumnicht may update this Privacy Notice. Sumnicht will notify the clients about material changes in the manner with which Sumnicht treats client nonpublic personal information. Although Sumnicht shall send its current Privacy Notice to the clients' attention annually, clients are encouraged to contact the Sumnicht office periodically to address any questions or concerns.

Should clients have any questions regarding the above, they should contact Mr. David E. Hackney, Chief Compliance Officer of Sumnicht, at the Sumnicht office.