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WE LET THE FACTS GET IN THE WAY OF OUR THINKING
PRIVACY POLICY/REGULATION S-P

Chlebina Capital views protecting its customers' private information as a top priority and, pursuant to the requirements of the Gramm-Leach-Bliley Act (the "GLBA"), Chlebina Capital has instituted the following policies and procedures to ensure that customer information is kept private and secure.

This policy serves as formal documentation of Chlebina Capital's ongoing commitment to the privacy of its customers. All employees will be expected to read, understand, and abide by this policy and to follow all related procedures to uphold the standards of privacy and security set forth by Chlebina Capital. This Policy, and the related procedures contained herein, is designed to comply with applicable privacy laws, including the GLBA, and to protect nonpublic personal information of Chlebina Capital's customers.

In the event of new privacy-related laws or regulations affecting the information practices of Chlebina Capital, this Privacy Policy will be revised as necessary and any changes will be disseminated and explained to all personnel.

A.    Scope of Policy

This Privacy Policy covers the practices of Chlebina Capital and applies to all nonpublic personally identifiable information of our current and former customers. This information includes, but is not limited to, names, addresses, e-mail addresses, account numbers, social security numbers, phone numbers, fax numbers, birth dates, and any other information that may be obtained by Chlebina Capital Management.

B.    Overview of the Guidelines for Protecting Customer Information

In Regulation S-P, the Securities and Exchange Commission (the "SEC") published guidelines, pursuant to section 501(b) of the GLBA, that address the steps a financial institution should take in order to protect customer information. The overall security standards that must be upheld are:

          1. Ensure the security and confidentiality of customer records and information;

          2. Protect against any anticipated threats or hazards to the security or integrity of customer records and information; and


          3. Protect against unauthorized access to or use of customer records or information that could result in substantial harm or   

           inconvenience to any customer.

     1. Employee Responsibility

          1. Each employee has a duty to protect the nonpublic personal information of customers collected by Chlebina Capital.

          2. No employee is authorized to disclose or use the nonpublic information of customers on behalf of Chlebina Capital.


          3. Each employee has a duty to ensure that nonpublic personal information of Chlebina Capital's customers is shared only with 

           employees and others in a way that is consistent with Chlebina Capital's Privacy Notice and the procedures contained in this Policy.

          4. Each employee has a duty to ensure that access to nonpublic personal information of Chlebina Capital's customers is limited as

           provided in the Privacy Notice and this Policy.

          5. No employee is authorized to sell, on behalf of Chlebina Capital or otherwise, nonpublic information of Chlebina Capital's customers.


          6. Employees with questions concerning the collection and sharing of, or access to, nonpublic personal information of Chlebina   

           Capital's customers must look to Chlebina Capital's CCO for guidance.

          7. Violations of these policies and procedures will be addressed in a manner consistent with other Company disciplinary guidelines.


     2. Types of Permitted Disclosures – The Exceptions

Regulation S-P contains several exceptions, which permit Chlebina Capital to disclose customer information (the "Exceptions"). For example, Chlebina Capital is permitted under certain circumstances to provide information to non-affiliated third parties to perform services on Chlebina Capital's behalf. In addition, there are several "ordinary course" exceptions, which allow Chlebina Capital to disclose information that is necessary to effect, administer, or enforce a transaction that a customer has requested or authorized. A more detailed description of these Exceptions is set forth below.

1.  Service Providers. Chlebina Capital may from time to time have relationships with nonaffiliated third parties that require it to share customer information in order for the third party to carry out services for Chlebina Capital. These nonaffiliated third parties would typically represent situations where Chlebina Capital or its employees offer products or services jointly with another financial institution, thereby requiring Chlebina Capital to disclose customer information to that third party.

Every nonaffiliated third party that falls under this exception is required to enter into an agreement that will include the confidentiality provisions required by Regulation S-P, which ensure that each such nonaffiliated third party uses and re-discloses customer nonpublic personal information only for the purpose(s) for which it was originally disclosed.

2.  Processing and Servicing Transactions. Chlebina Capital may also share information when it is necessary to effect, administer, or enforce a transaction for our customers or pursuant to written customer requests. In this context, "Necessary to effect, administer, or enforce a transaction" means that the disclosure is required, or is a usual, appropriate, or acceptable method:

     1. To carry out the transaction or the product or service business of which the transaction is a part, and record, service, or maintain the consumer's
      account in the ordinary course of providing the financial service or financial product;

     2. To administer or service benefits or claims relating to the transaction or the product or service of which it is a part;


     3. To provide a confirmation, statement, or other record of the transaction, or information on the status or value of the financial service or financial

      product to the consumer or the consumer's agent or broker; or

     4. To accrue or recognize incentives or bonuses associated with the transaction that is provided by Chlebina Capital or any other party.


C.  Sharing as Permitted or Required by Law.

Chlebina Capital may disclose information to nonaffiliated third parties as required or allowed by law. This may include, for example, disclosures in connection with a subpoena or similar legal process, a fraud investigation, recording of deeds of trust and mortgages in public records, an audit, or examination, or the sale of an account to another financial institution.

Chlebina Capital has taken the appropriate steps to ensure that it is sharing customer data only within the above noted Exceptions. Chlebina Capital has achieved this by understanding how Chlebina Capital shares data with its customers, their agents, service providers, parties related to transactions in the ordinary course or joint marketers.

D.  Safeguarding of Client Records and Information

Chlebina Capital has implemented internal controls and procedures designed to maintain accurate records concerning customers' personal information.  Chlebina Capital's customers have the right to contact Chlebina Capital if they believe that Company records contain inaccurate, incomplete, or stale information about them. Chlebina Capital will respond in a timely manner to requests to correct information. To protect this information, Chlebina Capital maintains appropriate security measures for its computer and information systems, including the use of passwords and firewalls.

Additionally, Chlebina Capital will use shredding machines, locks and other appropriate physical security measure to safeguard client information stored in paper format. For example, employees are expected to secure client information in locked cabinets when the office is closed.

Chlebina Capital protects confidential client information including but not limited to consumer report or any compilation of consumer report information derived from a consumer report by maintaining some information in locked filing cabinets and shredding such information when then information is no longer needed by Chlebina Capital.

E.   Security Standards

Chlebina Capital maintains physical, electronic, and procedural safeguards to protect the integrity and confidentiality of customer information. Internally, Chlebina Capital limits access to customers' nonpublic personal information to those employees who need to know such information in order to provide products and services to customers. All employees are trained to understand and comply with these information principles.

F.  Privacy Notice

Chlebina Capital has developed a Privacy Notice, as required under Regulation S-P, to be delivered to customers initially and on an annual basis. The notice discloses Chlebina Capital's information collection and sharing practices and other required information and has been formatted and drafted to be clear and conspicuous. The notice will be revised as necessary any time information practices change. 

      1. Privacy Notice Delivery

          1. Initial Privacy Notice - As regulations require, all new customers receive an initial Privacy Notice at the time when the customer
           relationship is established, for example on execution of the agreement for services.

          2. Annual Privacy Notice - The GLBA regulations require that disclosure of the Privacy Policy be made on an annual basis. Chlebina
           Capital will deliver its annual Privacy Notice in conjunction with the annual offer of its Form ADV Part II.

      2. Revised Privacy Notice

Regulation S-P requires that Chlebina Capital amend its Privacy Policy and distribute a revised disclosure to customers if there is a change in Chlebina Capital's collection, sharing, or security practices.