As required by the Securities and Exchange Commission and the Federal Trade Commission, the Privacy Policy below explains our handling of the information that we have in our records that is personal and private to you. It reiterates our commitment to keeping that information private.

Information We Collect

In the course of doing business with you, we collect nonpublic information about you from the following sources:

• Information we receive from you on applications or other forms, such as your social security number, personal financial information, occupation, and birth date;

• Information about your transactions with us, our affiliate, or others such as payment history, account balance, assets, and past transactions with us; and

• Information we collect from you through your account inquiries by mail, e-mail, or telephone.

Disclosure of Information to Nonaffiliated Third Parties

We do not disclose any nonpublic personal information about our customers or former customers to any nonaffiliated third parties, except with prior consent or as permitted by law. Disclosures permitted by law include information to our service providers, such as transfer agents, custodians, shareholder communications firms, technology consultants, clearing firms, and certain broker-dealers. As a rule, we only provide this information to those entities whose services are necessary for us to properly fulfill our investment services to you. We only share with these service providers the information they need to provide these services and they are required to use this information only to provide the services.

Disclosure of Information to Affiliates

Helmsman Financial Group, LLC, is affiliated with Miller Rieke Whitsell & Co. P.S., CPA’s and Herb Sprute Inc., CPA. We may share your personal information with these affiliates for the purpose of professional advice as it pertains to taxation or other professional service questions. Such personal information will not be shared with our affiliates for any other purpose, such as marketing or other business activities. Neither we nor our affiliate shares any of this information with any other entities.

Security Standards

We maintain physical, electronic, and procedural safeguards to ensure the integrity and confidentiality of your nonpublic personal information in the manner described above.

Disclaimer