BASE collects nonpublic personal information about clients from a number of sources. It collects information from clients and their designated agents, from consumer and business reporting agencies, from brokers, dealers, custodians and from public sources. BASE uses this information to form an opinion about suitability, to clear trades and generally to operate client accounts as investment adviser.

BASE does not disclose nonpublic personal information about clients to anyone except as permitted by law or as specifically directed by those clients. If a client decides to close an account, or become an inactive customer, BASE will continue to adhere to the same privacy policy relative to that account as described herein. Internally, BASE restricts access to client personal and account information to those employees who need to know that information so that BASE can accomplish its fiduciary responsibilities on its clients' behalf. If Mr. Hogle should end his association with BASE, both Mr. Hogle and BASE would be in possession of client nonpublic personal information, subject in both cases to the privacy policy described herein. BASE maintains reasonable physical, electronic and procedural safeguards to guard client nonpublic personal information.

As a matter of law, BASE may receive and share such personal information from and with brokers, dealers, custodians, regulators, court systems in any relevant jurisdiction, and specified interested parties on a need to know basis without specific authority from clients. BASE and its employees will need written authorization in order to communicate nonpublic personal or financial information to other client agents such as a CPA, a lawyer or other business or personal contacts with whom clients would like BASE to share. BASE is not adverse to using electronic means of communication; however, electronic communication is not private. BASE will need specific written authority from clients in order to send information to them or to their designated agents via electronic means.

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