PRIVACY POLICY STATEMENT

Berkeley Capital Management, LLC is a registered investment advisor. As a client of this firm, you should be aware of the firm’s policies regarding our use of the information you provide us when establishing or while maintaining a relationship with us. Berkeley maintains an information security program to reduce the risk that your personal and confidential information may be breached.

PRIVACY NOTICE

Berkeley Capital Management, LLC does not sell personal information about our clients to anyone. We will not share personal information about our clients with other companies unless we need to share the information in order to provide a product or service a client has requested. Unless we tell clients otherwise, these other companies do not have the right to use clients’ personal information obtained from our firm in any manner beyond what is required to provide a client’s requested product or service. Our firm limits the collection of personal information to what is necessary to administer our business and to deliver our products and services to our clients. It is usually necessary in the conduct of our business that we share information with our affiliates, custodians or broker-dealers or 3rd parties that clients may direct Berkeley to utilize. We do reserve the right to disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities, to perform necessary credit checks or collect or report debts owed to us, to protect our rights or property, or upon reasonable request by the sponsor or provider of a product in which you have chosen to invest. Listed below is the information we do collect and how we use that information:

Forms you may complete and/or provide us to interact with our company such as:

These forms may request personal information such as your e-mail address, telephone number, mailing address, financial information, employment information, investment objectives and financial needs, and pension information for example.

How we use this information

Your personal information is generally organized according to your name by Berkeley Capital Management, LLC. We use your personal information for the purpose of conducting business with you. At no time do we sell your information or share it unless it is necessary to conduct business with you. On occasion, our clients' service providers such as accountants, attorneys, etc. may request non-public information about them. We will upon request and upon notification to our clients supply such provider with such information.

Protection of Client Information

Our firm’s policies require that employees with access to confidential client information may not use or disclose the information except for business use. Access to client information is available to employees on a "need-to-know" basis only and is restricted to certain employees, representatives and agents with a business reason for access to such information. We safeguard information according to established security standards and procedures and train our employees and representatives to understand and comply with these protections.

Berkeley client’s nonpublic information is protected by physical safeguards, e.g. restricted access, shredding of documents, and electronic safeguards such as password protection. Berkeley may contract with a third-party vendor for off-site, independent computer back-up and storage of company files. Protection of sensitive files and highly-restricted, encrypted-online access to broker order placement and account records for advisors who are registered with custodians.

One significant concern that has driven recent regulations regarding the confidentiality and privacy of customer information is identity theft. While some of the recent, high-profile cases of identity theft involve unauthorized access to electronic information, some recent reports indicate that the majority of identity theft cases are still committed with information obtained offline. Berkeley’s procedures do not focus solely on the use of electronic information, but also address the proper use and destruction of paper documents that could raise privacy concerns.

As the Firm updates its technology and uses new and different methods of communication, whether through the use of wireless technology or allowing employees to work remotely, we will consider whether these methods necessitate updates or changes in our policies and procedures.

We will consider the following, at a minimum:

The use of new technologies can benefit the Firm, our employees, and customers; however, these new technologies can also present risks that we must consider and address appropriately. In some instances, the appropriate way to deal with these risks is not only through technological solutions, but may also involve changes to our training regimen and/or to our policies and procedures. We will consider whether the adoption of new technologies would necessitate changes in our compliance policies and procedures or systems before implementation so that issues can be identified and addressed in a timely way and problems can be avoided.

E-mail at Berkeley Capital Management

Berkeley Capital Management, LLC may rely on E-mail as a means of communication between our firm and our clients.

Changes to Firm Privacy Policies

From time to time the firm may update its privacy policies. All new clients will receive the most current privacy policy upon entering into an agreement or opening an account with the firm. All clients will be provided with the most current privacy policies at least annually.

Maintaining the Accuracy of Client Information

Keeping client account information accurate and up to date is very important to us. If you ever find that your account information is incomplete, inaccurate or not current, please email or write us at the locations listed below. We will correct any inaccurate or outdated information as soon as possible.

Contacting Us

You may contact us by telephone at: (785) 472-2375

You may contact us by email at: info@berkeleycapitalmanagement.com

Or you may also communicate with us in writing at:

Berkeley Capital Management, LLC
PO Box 237
Ellsworth, KS 67439