SRA PRIVACY POLICY

PRIVACY POLICY Security Research Associates, Inc. takes great care to safeguard the privacy of the personal information that we collect about our customers. This notice is provided to you so that you will understand what personal information we collect and how we use it.

We may collect non-public personal information from you from the following sources:
1. Information that you provide to us during the account application process and to update your account records. This may include your name, address, Social Security number, employment and financial information.
2. Information we collect from third parties. This may include such things as the market value of your account and the results of transactions that you instruct us to place, which we obtain from the clearing broker/dealers with whom we have established relationships and data that we may obtain from non-affiliated third parties, including consumer and industry reporting agencies, and;
3. Information that we create and retain based on your investment experience with us. This may include records of orders placed for your account and the results of those transactions. SRA uses the non-public information we collect to help us determine the suitability of our recommendations, as a tool in obtaining your investment objectives and to satisfy the requirements of various regulatory entities.

SRA has adopted policies and procedures designed to safeguard your non-public personal information about existing or former customers to non-affiliated third parties. Only properly authorized employees are permitted access to non-public personal information. Our company records are kept in locations we consider to be secure. We use technology that is designed to protect the privacy of the information transmitted and received.

It is our policy not to disclose nonpublic personal information about existing or former customers to non-affiliated third parties, except as permitted by law. However, we do disclose and will continue to disclose such non-public personal information to non-affiliated third parties in response to a subpoena for records, to assist regulators and law enforcement agencies to prevent actual or potential fraud, money laundering, acts of terrorism or other illegal activity, to comply with an inquiry by a government agency or other regulator or as necessary for other legal purposes.

SRA strives to keep your records accurate and to make appropriate corrections when you notify us. Please let us know if there is incorrect information in any statements or other communications that you receive from us.

We may modify our privacy policies in the future. If we do so, we will communicate any material changes to you as required by law. You should be aware that other parties with whom you have a relationship may have different privacy policies.