In connection with your investment account and providing investment management services to you, Cunningham Asset Management, LLC. (CAM) obtains certain nonpublic personal information including your name, address, social security number, investment objectives and experience, financial suitability, employment and other information. This information is used internally to provide you with the services that you request. Our policy is to keep this information confidential to the maximal extent possible.

Within CAM, access to nonpublic personal information regarding investors is limited to those employees who need the information to appropriately provide CAM's services most efficiently. CAM does not provide nonpublic personal information to any third party without prior written consent from the investor.

CAM protects nonpublic personal financial information it may collect by maintaining physical, electronic, legal and procedural safeguards designed to protect the security and confidentiality of your information. These include confidentiality policies with our employees, document storage and destruction procedures, and password-protected user access to our computer files and system. Our privacy policy applies equally to former and current investors.