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Compass Capital Management, Inc. (“Compass”) is committed to maintaining the privacy of current and prospective clients. Compass recognizes that you entrust it with highly confidential personal and financial information, and Compass understands that protecting and safeguarding this information is important.

In the course of establishing a client relationship and in its ongoing dealings with you as a client, Compass may obtain nonpublic personal information about you. This information may include your name, address, telephone number, e-mail address, social security number, taxpayer identification number, account numbers, income, transaction history, and other personal information.

In order to run its everyday business, Compass needs to share nonpublic personal information about its clients. Compass does not disclose any nonpublic personal information about clients to any nonaffiliated parties, except third-party service providers that assist in the operation of its business. To provide necessary business services to your account, Compass may disclose nonpublic personal information to service providers such as custodians and brokerage firms, all of which are required to maintain the confidentiality of such information. Compass restricts access to nonpublic personal information about you to those employees, agents, or other parties that need to know the information to provide services to you. Compass may also release information about you upon your direction or if compelled by law to do so.

Compass has adopted the following privacy policy in order to safeguard the personal information of Compass’s clients in accordance with applicable law:

(1)   Compass is committed to protecting the confidentiality and security of the information it collects and will handle nonpublic personal information about clients only in accordance with all applicable laws, rules and regulations.

(2)   Compass will maintain policies and procedures that are reasonably designed to safeguard nonpublic personal information about clients and only permit appropriate and authorized access to, and use of, nonpublic personal information about clients through the application of appropriate administrative, technical, and physical protections.

(3)   To the extent required by applicable law, Compass shall direct each of Compass’s service providers to adhere to the privacy policy of Compass with respect to all nonpublic personal information about clients provided to such service providers.

(4)   Compass shall not disclose any nonpublic personal information about its clients or former clients to anyone, except as permitted or required by law.

(5)   Compass shall issue notices of its privacy policy to its clients initially and on an annual basis thereafter to the extent required by applicable law.

BY DISCLOSING YOUR PERSONAL INFORMATION TO COMPASS, YOU CONSENT TO THE COLLECTION, STORAGE, AND PROCESSING OF THIS INFORMATION BY COMPASS IN A MANNER CONSISTENT WITH THIS PRIVACY POLICY.