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,
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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