Vickerman Investment Advisors (VIA) Privacy Policy follows and is applicable to current and former clients. Throughout the policy, VIA refers to information that personal- ly identifies clients or client accounts as "personal information." VIA collects personal information in the normal course of business to better manage and serve Clients. (1) VIA collects Clients’ information (that they provide VIA) when they open an Account. The information VIA collects may include the Client’s name, address, phone number, e-mail address, social security number, and information about the Cli- ent’s interests, investments, financial goals and investment experience. (2) Once a Client opens an Account with VIA, personal information is collected and maintained about the Client’s transaction history, positions, and account balances. VIA may include the Client’s name and other data in internal databases and lists that reflect the client’s activities with VIA.

VIA uses personal information to fulfill regulatory and audit obligations and to help VIA deliver the best possible client service. VIA does not sell personal information to anyone. VIA does not disclose personal information to third parties, unless one of the following limited exceptions applies: (1) VIA discloses personal information to companies that help us process or service client transactions or Account(s), including, but not limited to the Custodian, data aggregation software, customer management software, etc. VIA has contracts with these companies that prohibit them from using personal information for their own purposes. (2) VIA may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required or permitted under law, for example: to cooperate with regu- latory or law enforcement authorities, to resolve consumer disputes, to perform credit/authentication checks, or for institutional risk control.

Outside of these exceptions, we will not share personal information with third parties unless the Client specifically requests us to do so.

VIA protects the confidentiality and security of personal information. (1) Companies VIA hired to provide support services are not al- lowed to use personal information for their own purposes. VIA limits their use of personal information to performance of the specific service we have requested. (2) VIA restricts access to personal information to employees and agents for business purposes only. (3) All employ- ees are trained and required to safeguard such information. (4) VIA maintains physical, electronic, and procedural safeguards for personal information.

VIA continues to evaluate our efforts to protect personal information and make every effort to keep personal information accurate and up-to- date. If Clients identify any inaccuracy in their personal information, or need to make a change to that information, they should contact VIA. If, at any time in the future, it is necessary to disclose our Clients’ personal information in a way that is inconsistent with this policy, advance notice of the proposed change will be provided to Client, so they can opt out of such information sharing.

Clients with any questions or concerns may call VIA at (509) 325-7610.