American Capital Partners, LLC is the Brokerage Firm in which you have an account.

Where we get information.

The information we collect about you comes primarily from you. This includes such information as your name, address and Social Security Number that you may have provided on applications, agreements or other forms. We maintain records of each of your transactions and holdings.

We may also obtain information about you, such as your credit history or other facts relating to creditworthiness, from a consumer-reporting agency.

To whom we disclose the information.

We provide information about current or former clients to our clearing firm from sources described to parties outside American Capital on as described below.

To other companies as necessary to process your business.

For example, we transmit your account and transactional information to our clearing firm. Third parties in this category, like those in the category above, must limit their use of the information to the purpose, which it was provided.

Where required by law or regulation.

Examples include responses to a subpoena, court order or regulatory demand.

As authorized by you.

You may direct us to send your account statements and trade confirmations to a third party or to our Registered Investment Advisor.

As otherwise authorized or permitted by law.

For example, the law permits us to respond to a request for information about you from a consumer-reporting agency.

Confidentiality and security.

We restrict access to information about you to those employees and authorized agents who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal standards to maintain the confidentiality of your iformation.