PRIVACY DECLARATION

Anchor Bay Capital, Inc. (“Anchor Bay”) recognizes that safeguarding our clients’ personal and financial information is a foundation of customer trust and sound business practice. Anchor Bay has created this Privacy Policy statement in order to demonstrate our firm commitment to the privacy of our clients’ information with respect to the anchorbaycapital.com website (“website”).

Anchor Bay may receive client personal and financial information from the following sources:

• Information our clients provide us on applications (e.g., name, address, Social Security number, birth date, assets, and income) or other forms or which may be publicly available;

• Information our clients direct or authorize us to obtain from third-party advisors or custodians (including investment, legal, insurance or other financial advisors, or brokerage houses, banks or asset custodians);

• Information that our clients give us verbally;

• Information about our clients’ financial transactions with us or others;

• Information about our clients from government agencies and law enforcement officials (e.g., for tax reporting or under court order);

• Information about our clients from transactional activity in their accounts (e.g., trading history and balances);

• Information about our clients from their other interactions with Anchor Bay (e.g., discussions with our customer support staff);

• Information about our clients from verification services and consumer reporting agencies (e.g., to ensure the accuracy of application data).

We may use this information in order to process transactions in our clients’ accounts, respond to inquiries from them or their representatives or fulfill legal and regulatory requirements.

• Anchor Bay doesn’t sell personal information that’s sent to us by our clients to anyone.

• Anchor Bay doesn’t disclose any personal or financial information about our clients or former clients without their express authorization or direction, except as provided by law, under valid process or as required in response to inquiries from governmental authorities.

• We will protect the confidentiality of any personal information our clients share with us and will limit the collection of information to that which is necessary to provide them with superior service.

• We restrict access to our clients’ personal and financial information to those Anchor Bay employees who have a reasonable need to know that information to provide the services to our clients.

• Email transmissions sent to our website aren’t secure. Information sent could be viewed in transit by a third party. We therefore request that our clients not send us or ask for sensitive information such as account numbers, PINs, or transaction information via our website email.

• Our website contains links to other websites. We are not responsible for the privacy practices or the content of such websites. Some services appearing on this website may be provided by third parties. We are not responsible for the privacy practices or the content of such third parties, even if visitors are not aware of the fact that they have left our website and entered a third party’s website.