We at Fridson Investment Advisors, LLC ("FIA") are fully committed to protecting the privacy of our clients. Keeping client and customer information secure is a top priority for all of us and we want to be straightforward about our information practices. Set forth below is a description of our privacy policy:

1. What information may be collected? How could it be used?
   We generally collect and use information about clients and customers in order to deliver quality service to them. Information may be obtained through agreements with clients and prospective clients, including subscription materials and any other applications or other forms submitted directly to us or through unaffiliated third parties, transactions with us or our affiliates, and meetings between clients and our employees, such as portfolio managers and/or account managers. This information might include a client’s name, address, social security number, assets, income and investment history or other personal information. We collect this information in order to advise clients and customers about our products, services, and other opportunities, to provide quality service, and to operate our business in conformance with our regulatory obligations.
   
   
2. Will any of the collected information be disclosed to others?
   Other than as required or permitted by law, we will not reveal client or former client information to any unaffiliated third parties unless we have previously informed the client in an agreement with the client, have provided disclosure to the client (with the opportunity to “opt-out”), or have otherwise been authorized by the client. All types of client and former client information may be shared with our affiliates and agents as is reasonably necessary to administer, service or otherwise maintain accounts and generally as permitted by law. The types of persons to whom such information may be disclosed include the employees of FIA, pooled investment vehicles managed by FIA, and their respective related legal entities, service providers, officers, directors, agents, sub-advisors, professional advisors and authorized representatives.
   
   
3. How is the collected information protected?
   We have several internal controls in place to protect the collected information. We consider the information confidential and proprietary, and as such we restrict access to such information.
   
   
4. Will this policy change in the future?
   The policy we have described here is current as of May 2008, but as circumstances or legal requirements change, FIA may need to amend its privacy policy in which event FIA will provide its clients with a revised notice describing such privacy policy changes.