Annual OSA Privacy Policy 2012

It is Ogilvie Security Advisors Corporation's ("OSA") goal to protect your privacy and the confidentiality of your personal information. In the regular conduct of our business, we may collect non-public personal information about you from sources such as:

• Applications and related forms or through disclosures to OSA representatives and staff (name, address, social security number, net worth, assets, etc.
• Your investment activity, such as your account statements and performance reports.
• Third parties in connection with the services we may provide to you.

Federal law requires us to collect and maintain personal information about you to verify your identity, which helps the government fight the funding of terrorism and prevent money laundering activities.

As OSA shares non-public information solely to service our customer accounts, we do not disclose any non-public personal information about our customers or former customers to anyone, except as provided by law. For example, among other reasons OSA may disclose or report such information: where necessary to authorize, effect, administer or enforce transactions that you request or authorize; to maintain and administer your account; to provide you with account confirmations, statements and records; to maintain appropriate archival records; where OSA believes that disclosure is required by applicable law, rules or regulations; to cooperate with law enforcement or regulatory or self-regulatory organizations; to enforce OSA's customer and other agreements; to meet OSA's other obligations, or to protect OSA's rights and property. To provide the utmost in service, we also may disclose the information we collect regarding customers and/or former customers, as necessary, to companies to perform certain services on your and our behalf or to other financial institutions with which we have joint marketing agreements, as they service your account, or as required by law. We may also disclose the information with unaffiliated entities in connection with a proposed or actual sale, merger, transfer or exchange of all or a portion of our business or other transaction or business combination.

Information Safeguarding - OSA internally safeguards your non-public personal information by restricting access to only those employees who provide products or services to you or who otherwise need to know such information or to companies who need access to your information to service your account or as described above. In addition, we maintain physical, electronic and procedural safeguards that meet federal and/or state standards to protect your non-public personal information. OSA does not sell or license lists of our customers or their personal, non-public information to any third parties.

Transferring Information to a New Firm -- If the representative servicing your account(s) leaves OSA to join another financial institution or is transferred by OSA, your representative may retain copies of your personal information so that he or she can continue to serve you at the new firm. If you do not want your representative to take your information with him or her should your representative leave OSA to join another firm, you have the right to opt out of such disclosure. If you have a joint account, we will treat an opt-out direction by a joint customer as applying to all associated joint customers. Some states have additional requirements designed to protect the privacy of your personal information. OSA will comply with these state requirements. If you wish to opt out, now or at any time in the future, please contact our Compliance Department by phone at 1-888-896-0020 or by mail at Ogilvie Security Advisors Corp., c/o Compliance Department, 71 S Wacker Drive, Suite 3025, Chicago, IL 60606.

For Vermont customers, if we disclose personal information about you to unaffiliated third parties with whom we have joint marketing agreements, we will only disclose your name, address, other contact information, and information about our transactions or experiences with you.

For California customers, we automatically treat accounts with California billing addresses as if you do not want to disclose personal information about you to unaffiliated third parties except as permitted by the applicable California law. We will also limit the sharing of personal information about you with our affiliates to comply with all California privacy laws that apply to us.

No action is required on your part. This notice is meant to inform you on how we safeguard your non-public personal information. You may wish to file this notice with your financial records.