PRIVACY POLICY

Confidentiality is a core value of Alpha Solutions Investment Advisors’ relationship with its clients.  Our commitment to safeguard your personal and financial information goes far beyond our legal and ethical obligations – your valued trust is extremely important to us.  A strict confidentiality policy is observed by all officers, directors and employees.  We limit access to your personal/financial information to only those employees with a business reason to know such information.  We train and consistently remind all employees to respect client privacy and to recognize the importance of the confidentiality of such information. Those who violate our privacy policy are subject to disciplinary action. Please be aware that all financial companies, in order to run their day-to-day operations, choose how to and need to share customers’ personal information.  We want you to understand what information we obtain, how we use it and how we protect your privacy.  We obtain nonpublic personal information about you directly from you and sometimes from third parties authorized by you to provide information to us and from your transactions with us or others. This information may be of a personal or family nature (such as the name, address, telephone number, FAX number, email address, social security number and date of birth of you and your family members) or of a financial nature (such as your assets, liabilities, income or expenses).  We do not disclose any nonpublic personal information about you to anyone, except as required by law, as authorized by you, or as part of our employment of third parties that assist us to either provide you the services which we furnish to you or to enhance these services. Accordingly, disclosures may be made pursuant to a subpoena or to our internal and external auditors, federal and state regulatory authorities and businesses which provide certain technological services to us.  Such entities have confidentiality policies of their own. Our privacy policy and practices continue even if you no longer receive services from us.  We have taken steps to ensure the electronic privacy of clients in our processing of transactions on their behalf, which we believe are effective, and we will continually review our procedures and controls in this regard. In addition, we maintain physical, electronic and procedural safeguards that comply with state and federal regulations to protect the privacy of your nonpublic personal information.  We also respect the privacy of users visiting our website and do not send unsolicited emails or any electronic or direct marketing materials.  We recognize that clients’ financial and personal information has been entrusted to us with the expectation that it will remain private, and we treat this responsibility seriously. Federal law requires us to inform you that we have on record personal information about you and that we obtain such information from you directly (e.g., information you provide to us on account applications and other forms, such as your name, address, social security number, occupation, assets and income) and indirectly (e.g., information on our computer systems about your transactions with us, such as your account balance and account holdings).  Any personal information you choose to provide is kept confidential and allows us to: (a) provide better and more complete investment and strategic advice; (b) recommend new services that meet additional needs you may have; and, (c) comply with legal and regulatory requirements.  Federal law gives consumers the right to limit some but not all sharing. In addition, in the normal conduct of our business, it may become necessary for us to share information relating to our clients that we have on record, as described above, with companies not affiliated with us who are under contract to perform services on our behalf.  For example, if we contract with companies such as: specialized sub-advisors in the management of your assets or custodians that provide custody of your assets we will be disclosing pertinent and personal information about you.  These companies may provide clearing services, and other vendors services directly related to your account relationship with us and will assist us in complying with KYC (Know Your Client), ATF (Anti-Terrorist Funding) and AML (Anti-Money Laundering) statutory requirements which may include the identification and reporting of activities that may involve terrorist acts or money laundering activities.  Our agreements with these companies require that they keep your information confidential and not use such information for any unrelated purpose. We do not sell information about you to third parties, and we do not otherwise disclose information to third parties without your permission or unless required by law.