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Privacy Policy

Staley Capital Advisers, Inc. respects your privacy and recognizes its obligation to safeguard your confidential information. Please read this notice carefully to understand what we do.

Staley Capital asks clients for non-public, personal information that we need in order to manage your investments and service your accounts. For example, social security numbers and financial account numbers are necessary to open or update financial accounts, to facilitate client requests for cash transfers or withdrawals, and produce certain tax documents. We also review your personal information prior to recommending certain investments as well as to comply with federal anti-money laundering requirements. Even if our relationship ends, we may continue to maintain your information for regulatory, reporting, or other purposes. These privacy policies, therefore, apply to the personal information of all prospective, current, and past clients of Staley Capital.

POLICY

Staley Capital never sells or shares your information with any third party for their use in marketing or research. Your identifiable personal information is used only in the management and servicing of your accounts. Staley Capital employees are required to act in accordance with our Code of Ethics, to treat your information with the utmost confidentiality, and to adhere to a culture respecting client privacy.

PROCEDURES

We have procedures in place that we believe are reasonably designed to protect your information. These procedures span all aspects of our business, from a secure file room to the use of multi-factor identification to a state-of-the-art firewall. Every Staley Capital employee must certify annually that he/she understands and will abide by these rules, including the mandatory utilization of physical, electronic and procedural safeguards to protect confidential client information.

We do share your information with third parties who assist us in providing services to your account, such as brokers and custodians. Certain companies that provide operational services to our business, such as IT providers and portfolio management software providers, also have access to your account information. Last, we share your information when necessary to meet our regulatory obligations or when legally required to do so. Anytimeweshareyourinformation, we make every effort to ensure that the recipient is obligated to safeguard your information, has appropriate data security measures in place, will use the information only for the intended purpose, and will abide by all applicable laws.

As we disclose your information only in limited situations which are necessary to the operation of our business or the servicing of your account, we do not provide an “opt-out” provision for clients.

CONTACT INFORMATION

Your business is important to us and everyone at Staley Capital is committed to maintaining the confidentiality, security and integrity of your personal information. If you have questions or concerns about our privacy policy, please contact our Chief Compliance Officer at 412-261-6892.