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It is the policy of Robert W. Colby Asset Management, Inc. to keep confidential information (i.e., nonpublic personal information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) pertaining to each current and former Client unless Colby is:

(1) previously authorized by the Client to disclose information to individuals and/or entities not affiliated with Colby, including but not limited to the Client's other professional advisers and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, etc.);

(2) required to do so by judicial or regulatory process; or

(3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. The disclosure of information contained in any document completed by the Client for processing and/or transmittal by Colby in order to facilitate the commencement, continuation, or termination of a business relationship between the Client and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by the Client for Colby (i.e., Colby's agreement, Client information form, etc.), shall be deemed as having been automatically authorized by the Client with respect to the corresponding nonaffiliated third party service provider.

Each individual and/or entity affiliated with Colby is aware of Colby's Privacy Policy, and has acknowledged his/her/its requirement to comply with same. In accordance with Colby's Privacy Policy, each such affiliated individual and/or entity shall have access to information to the extent reasonably necessary for Colby to perform its services for the Client and to comply with applicable regulatory procedures and requirements.

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