PRIVACY MATTERS

Kirk R. Sheldon and CAPITAL FINANCIAL MANAGEMENT take your personal privacy very seriously.  Because we value our client relationship with you, maintaining your privacy is important to us and your personal information is kept secure.  A new Federal law permits banks, investment companies and insurance companies to provide financial services.  This same law requires us to share our "Notice of Privacy Policy" with you.  You have a right to know what information is being collected about you and how that information will be used.

We collect nonpublic personal information about you from the following sources:

• Information we receive from you on applications or other forms, and
• Information about your transactions with our affiliates, others or us.

We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law.  Under the law, the information we collect is provided to companies that perform support services on our behalf as necessary to affect, administer, or process a transaction, or for maintaining and servicing your account.  This includes financial service providers, such as banks, securities broker-dealers, and insurance firms, etc.

We do not give or sell information about you or your account to any other company, individual or group.  Upon client approval or direction, we may share information with allied professionals such as your accountant, tax preparer, attorney or insurance professional.

We restrict access to nonpublic personal information about you to those employees who need to know the information to provide products or service to you.  We maintain physical, administrative and technical procedural safeguards to protect your nonpublic personal information.

We have established safeguards to protect the security and confidentiality of customer records and information.

Physical Security - Employees are to shred discarded paper records.  Employees are to erase/destroy electronic media before discarding.  The computer is secure and restricted to employee and authorized personnel access only.  The office is secure and restricted from access by outside parties when employees are not present.

Administrative Security - Your Registered Investment Advisor is the designated person responsible for monitoring internal access to customer records and information and determining who has access rights to covered information.  Your Registered Investment Advisor will periodically identify and assess the risks that may threaten protected information and adjust procedures to account for changes in technology, the sensitivity of the protected information, and internal or external threats to information security.  Your Registered Investment Advisor shall train employees in record safeguarding and record disposal.

Technical Safeguards - All employees have or will enter into a confidentiality agreement upon employment.

Employees shall take other reasonable steps in protecting customer records as may be necessary from time to time.

You do not need to call or do anything as a result of this notice.  It is meant to inform you of how we safeguard your nonpublic personal information. 

Thank you for choosing to do business with us.  Your patronage is valued.  Your confidence in us is important and we want you to know that your personal and account information is safe.  Your understanding is greatly appreciated.