ROSENBLUM-SILVERMAN-SUTTON, S.F., INC.
STATEMENT OF PRIVACY POLICY

 Our Commitment to Your Privacy:  Protecting our clients’ privacy is very important to Rosenblum-Silverman-Sutton, S.F., Inc. (“RSS”).  We will not share nonpublic personal information about our clients with nonaffiliated third parties without prior client consent, except for specific purposes described below.  This notice explains our collection, use and safeguarding of client information.

 How RSS Gathers Information:  In connection with providing clients with investment management services, we may obtain information about them from the following sources:

■ Client Investment Management Agreements and other information that clients provide to us, whether in writing, in person, by telephone, electronically or by any other means. This information may include a client’s name, address, phone number, e-mail address, social security number, employment information, income, investment experience, and credit references;
■ Transactions on a client’s behalf. This information may include the client’s account balances, positions, investment interests and history;
■ Consumer reporting agencies. This information may include account information and credit history; and
■ Public sources.

 Sharing Information with Nonaffiliated Third Parties:  We only disclose non-public client information to nonaffiliated third parties without prior client consent when we believe it necessary for the conduct of our business or as required or permitted by law, such as:

■ If you request or authorize the disclosure of the information;
■ To respond to a subpoena or court order, judicial process, law enforcement or regulatory authorities;
■ To perform services for the firm or on its behalf to develop or maintain proprietary trading or other software;
■ In connection with a proposed or actual sale, merger, or transfer of all or a portion of our business or an operating unit; and
■ To help us prevent fraud.

 In addition, RSS may disclose any nonpublic client information to service providers who maintain or service client accounts for us in order for us to be able to provide clients with necessary services with respect to their accounts, such as:

■ To help us process an application to become a client or service a client’s account;
■ To enable them to provide business services to us;
■ To facilitate the processing of transactions for client accounts;
■ To assist us in performing marketing services or offering products or services to clients; and
■ For credit review and reporting purposes.

 The information provided to these service providers may include the categories of information described above. These service providers are not allowed to use client personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We also limit their use of client personal information to the performance of the specific service we have requested.

 Except in those specific, limited situations, without your consent, we will not make any disclosure of client nonpublic personal information to other companies who may want to sell their products or services to you. For example, we do not sell client lists and we will not sell client names to catalogue companies.

 Opt Out Provision:  If, at any time in the future, it is necessary to disclose any of client personal information in a way that is inconsistent with this policy, we will give our clients advance notice of the proposed change so that they will have the opportunity to opt out of such disclosure.

Former Clients:  Our Privacy Policy will continue to apply to all former clients.

 To Whom This Policy Applies:  This Privacy Policy applies to individuals who obtain or have obtained service from RSS, used primarily for personal, family, or household purposes.

 Our Security Practices and Information Accuracy:  We also take steps to safeguard client information. We restrict access to the personal and account information of our clients to our employees and agents for business purposes only. We maintain physical, electronic, and procedural safeguards to guard your personal information.

 We also have internal controls to keep client information as accurate and complete as we can.  If you believe that any information about you is not accurate, please let us know.

 Other Information:  We reserve the right to change this Statement of Privacy Policy. The examples contained within this Privacy Policy are illustrations and they are not intended to be exclusive.  If you have any questions about our Privacy Policy, please contact Michael Stephens (415) 771-4500.