Horizons West Capital Partners Confidentiality Notice

Horizons West Capital Partners, LLC (“HWCP”), like other professional service firms that advise on personal financial matters, is required by federal law to inform its clients of its policies regarding the privacy of client information. HWCP is committed to maintaining the confidentiality and security of our client’s personal and private information. Any violation of the HWCP Privacy Policy by an employee or associate of HWCP is grounds for immediate termination, subject to all applicable employment law and/or Federal or State regulations.

INFORMATION WE COLLECT

In the normal course of providing clients with investment advisory advice, HWCP may receive or be in receipt of certain non-public, personally identifiable financial and/or private information from its clients, their financial representatives and/or other third party delegates. HWCP may also gather information about clients during the normal course of its business from various forms or other applications, or from transactions clients conduct with HWCP and/or its affiliates, or that HWCP may place on clients’ behalf. HWCP collects and uses this information for the sole purpose of offering the highest quality investment advisory services to clients.

INFORMATION WE DISCLOSE

All non-public information that we directly or indirectly receive regarding our clients or former clients is held in the strictest confidence in accordance with our professional and legal obligations, and is not released to people outside HWCP except with the client’s written consent, as otherwise set forth herein or as required by law. We may disclose some or all of the information we collect, as described above, to certain nonaffiliated third parties such as attorneys, accountants, auditors and persons or entities who assist us in our business or who are assessing our compliance with industry standards and SEC and/or State Regulations. We may also disclose information to regulators or other governmental entities as permitted or required by law.

Your nonpublic personal information is used only for our business purposes, and we do not sell client information to anyone under any circumstances. At your direction, we may share certain information with related or affiliated entities or third parties who assist us with providing our services including outsourced service providers located outside of the United States.

CONFIDENTIALITY AND SECURITY

Within HWCP, access to a client’s non-public information is restricted to those individuals who require that information in the ordinary course of servicing a client’s account. Where a client’s non-public information is shared or reviewed by any nonaffiliated third party, HWCP will review that nonaffiliated third party’s privacy policies on a best efforts basis to insure such policies prohibit such third parties from disclosing or using the information other than to carry out the purposes for which we may disclose the information.

This Privacy Policy is not applicable to, and we are not responsible for, the privacy practices of any third party websites to which this website may link. Please familiarize yourself with the privacy policies of any third-party websites you visit, as they will govern any information collected by those websites.

In order to guard your non-public personal information from unauthorized disclosure, we maintain the physical, electronic, and procedural safeguards that comply with our professional standards as well as the applicable law to guard your nonpublic personal information at all times. With respect to online privacy, we employ certain internet specific practices to maintain the security of your online sessions, including but not limited to firewall barriers, encryption and authentication procedures.

In the event that these policies change, HWCP will provide you with a sufficient amount of time to opt out of any disclosure provisions should that be desired. Nevertheless, HWCP will provide a copy of its annual privacy notice to all clients upon inception of our investment advisory services. In addition, each of our active clients shall be provided with a copy of our privacy notice within ninety (90) days following the close of HWCP’s fiscal year.

The HWCP Privacy Policy is effective as of 7/1/09.