PRIVACY NOTICE

Gruppo, Levey & Co. and our affiliates seek to maintain the highest standards of confidentiality to safeguard the privacy of our clients. We are providing this Privacy Notice to all our clients who obtain investment or financial products and services from us, in accordance with Title V of the Gramm-Leach-Bliley Act of 1999 and its implementing regulations.

Information About You

The non-public personal information we may retain about you (your “Information”) comes primarily from any account applications, subscription agreements, questionnaires, emails, or other documents that you may submit to us. We may also internally record Information about your investments and experiences with us, our affiliates, and others relating to the products and services we provide.

Our Privacy Policies

We do not disclose your Information to anyone, except as permitted by law. Thus, we may share your Information (a) with our affiliates, in order to bring you the full range of services and products available from the Gruppo, Levey & Co., family of companies, and (b) with non-affiliated companies, in order to process your transactions with us or our affiliates or to perform accounting or other support services for your account. Additionally, we may disclose your Information if you give your specific consent or instruction to us, or if the disclosure is required by law or regulations. Our privacy policy applies to current and former clients, as well as potential clients.

Our Internal Information Security

We limit access to your Information to those of our staff and service providers who are involved in offering or administering the investments, products and services that we offer. We maintain physical, electronic, and procedural safeguards designed to comply with federal standards to protect your Information. We value our relationship with you and want to assure you that maintaining your privacy is important to us. If you have any question, please call Harry Chevan at (212) 697-5753.