Best Minds, Inc. strongly believes in protecting the confidentiality and security of information we collect about individuals. This notice describes the privacy policy followed by Best Minds, Inc.

INFORMATION WE COLLECT

“Nonpublic Personal Information” is nonpublic information about the Individual that we obtain in connection with providing a financial product or service to the Individual for personal, family, or household purposes.

We collect Nonpublic Information about Individuals from the following sources:

• Information provided to us directly by an Individual on an application or other form in connection with our products or services. This may include but not be limited to: name, address, social security number, assets, and income.
  
• Information about an Individual’s transactions with us, as well as various cash flow and net worth information such as account balance, debt information, estate planning documents, business statements, and tax returns.
  
• All information given by an institution as part of a relationship is NEVER given out to any other parties.

INFORMATION DISCLOSURE TO THIRD PARTIES

Best Minds, Inc. will not share such information with any nonaffiliated third party except:

•  When necessary to complete a transaction in a customer account, such as with    the clearing firm, account custodians or other service providers;
  
• When required to maintain or service a customer account;
  
• To resolve customer disputes or inquiries;
  
• With persons acting in a fiduciary or representative capacity on behalf of the   customer;
  
• With rating agencies, persons assessing compliance with industry standards, or  
     to the attorneys, accountants and auditors of the firm;
  
• In connection with a sale or merger of the firm’s business;
  
• To protect against or prevent actual or potential fraud, identity theft, unauthorized   transactions, claims or other liability;
  
• To comply with federal, state or local laws, rules and other applicable legal   requirements;
  
• In connection with a written agreement to provide investment management or   advisory services when the information is released for the sole purpose of
    providing  the products or services covered by the agreement;
  
• In any circumstances with the customer’s instructions or consent.

DISCLOSURE OF INFORMATION ABOUT FORMER CUSTOMERS

If an Individual decides to close an account or otherwise becomes an inactive customer, we will continue to follow the privacy practices described in this notice with respect to such Individual.

PROTECTING CONFIDENTIALITY AND SECURITY

We treat Information in a confidential manner. Our employees are required to protect the confidentiality of Information. We limit employee and agent access to information only to those who have a business or professional reason for knowing, and only to nonaffiliated parties as permitted by law.

We maintain a secure office and computer environment to ensure that your information is not placed at unreasonable risk.

Employees are subject to disciplinary rules if they do not comply with our policies.

Personally identifiable information about you will be maintained during the time you are a client, and for the required time thereafter that such records are required to be maintained by federal and state securities laws, and consistent with the CFP Board Code of Ethics and Professional Responsibility. After this required period of record retention, all such information will be destroyed.

We also maintain physical, electronic, and procedural safeguards to protect Information; these safeguards comply with all applicable laws. Our commitment to data security involves monitoring new advances in security technology and enhancing our security architecture to ensure that we provide the highest level of privacy and safety available for investment services firms and for our customers.