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Fleetwood Asset Management Ltd. has adopted a privacy policy with recognition that protecting

the privacy and security of the personal information we obtain about our clients and potential

clients is an important responsibility. We also know that our clients expect us to service them in

an accurate and efficient manner. To do so, we must collect and maintain personal information

about them. We want our clients to know what information we collect and how we use and

safeguard that information.

What Information We Collect

We collect certain nonpublic personal identifying information about our clients (such as their

name, address, social security number, etc.) from information that they provide on applications or

other forms as well as communications (electronic, telephone, written or in person) with them or

their authorized representatives (such as their attorney, accountant, etc.). We also collect

information about their brokerage accounts and transactions (such as purchases, sales, account

balances, inquiries, etc.).

What Information We May Disclose

We do not disclose the nonpublic personal information we collect about our clients to anyone

except in furtherance of our business relationship with them and then only to those persons

necessary to effect the transactions and provide the services that they authorize (such as

broker-dealers, custodians, independent managers, etc.) or as otherwise provided by law. We

are permitted by law to disclose the nonpublic personal information about our clients to other

third parties in certain circumstances (such as third parties that perform administrative or

marketing services on our behalf or for joint marketing programs). These third parties are

prohibited to use or share the information for any other purpose. If our customers decide at

some point to either terminate our services or become an inactive client, we will continue to

adhere to our privacy policy, as may be amended from time to time.

Security of our Clients' Information

We restrict access to our clients' nonpublic personal information to those employees who need

to know that information to service their account. We maintain physical, electronic and

procedural safeguards that comply with applicable federal and state standards to protect their

nonpublic personal information.

Changes to our Privacy Policy or Relationship with our Clients

Our policy about obtaining and disclosing information may change from time to time. We will

provide our clients with notice of any material change to this policy before we implement the

change. Clients may request a copy of Fleetwood Asset Management Ltd.'s Privacy Policy by

contacting Joan M. Guccione, President of Fleetwood Asset Management Ltd., at (203) 878-


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