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PRIVACY POLICY

Effective: January 31, 2013

Our Commitment to You

Contrast Capital Management, LLC ("Contrast Capital") is committed to safeguarding the use of your personal information that we have as your Investment Advisor. Contrast Capital (also referred to as "we", "our" and "us" throughout this notice) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything we can to maintain that trust.

Contrast Capital does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and proper business purposes in connection with the servicing and management of our relationship with you as discussed below.

Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Privacy Policy.


Why you need to know?
Registered Investment Advisors ("RIAs") share some of your personal information. Federal and State laws give you the right to limit some of this sharing. Federal and State laws require RIAs to disclose how we collect, share, and protect your personal information.


What information do we collect from you?
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number(s) Income and expenses
E-mail address(es) Investment activity
Account information (including other institutions) Investment experience and goals


What sources do we collect information from in addition to you?
Custody, brokerage and advisory agreements Account applications and forms
Other advisory agreements and legal documents Investment questionnaires and suitability documents
Transactional information with us or others Other information needed to service account


How we share your information?
RIAs do need to share personal information regarding its clients to effectively implement the RIA's services. In the section below, we list some reasons we may share your personal information.


Basis for sharing Sharing Limitations
Servicing our Clients
We may share non-public personal information with non-affiliated third parties (such as brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed services to you consistent with applicable law, including but not limited to:
  • Processing transations;
  • General account maintenance;
  • Responding to regulators or legal investigations; and
  • Credit reporting, etc.
Contrast Capital may share this information. Clients cannot limit the Advisor's ability to share.
Administrators
We may disclose your non-public personal information to companies we hire to help administrate our business. Companies we hire to provide services of this kind are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to the performance of the specific service we have requested.
Contrast Capital may share this information. Clients cannot limit the Advisor's ability to share.
Marketing Purposes
Unless you explicitly allow Contrast Capital to use your name on client lists, we do not disclose personal information with non-afffiliated third parties to offer you services. Certain laws may give us the right to share your personal inforomation with financial institutions where you are a customer and where Contrast Capital or the client has a formal agreement with the financial institution.We will share information for purposes of servicing your accounts or for marketing purposes (by including your name on client lists) if you explicitly allow us to do so.
Contrast Capital does not share personal information. Clients cannot limit the Advisor's ability to share.
Authorized Users
In addition, your non-public personal information may also be disclosed to you and persons we believe to be your authorized agent or representative.
Contrast Capital does share personal information. Clients can limit the Advisor's ability to share.
Information About Former Clients
Contrast Capital does not disclose, and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our clients.
Contrast Capital does not share personal information regarding former clients Clients can limit the Advisor's ability to share.


How do we protect your information?
To safeguard your personal information from unauthorized access and use, we maintain physical, procedural and electronic safeguards. These include computer safeguards such as passwords, secured files and buildings.
Our employees are advised about Contrast Capital's need to respect the confidentiality of each client's non-public personal information. We train our employees on their responsibilities.
We require third parties that assist in providing our services to you to protect the personal information they receive. This includes contractual language in our third party agreements.


Changes to our Privacy Policy
We will send you notice of our Privacy Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise our Privacy Policy, and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing.


Changes to our Privacy Policy
Massachusetts In response to a Massachusetts law, clients must "opt-in" to share non-public personal information with non-affiliated third parties before any personal information is disclosed. We may disclose non-public personal information to other financial institutions with whom we have joint business arrangements for proper business purposes in connection with the management or servicing of your account.


Questions: You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (617) 523 0104

20 Park Plaza, 4th Floor, Boston, MA 02116

Phone: (617) 523-0104

info@contrastcap.com