Risk Disclaimer & Privacy Policies

Risk Disclaimer | Privacy Policy

RISK DISCLAIMER

DISCLAIMER: Please remember that past performance may not be indicative of future results. Different types of investments involve varying degrees of risk, and there can be no assurance that the future performance of any specific investment, investment strategy, or product made reference to directly or indirectly in this bulletin, will be profitable, equal any corresponding indicated historical performance level(s), or be suitable for your portfolio. Due to various factors, including changing market conditions, the content may no longer be reflective of current opinions or positions. Moreover, you should not assume that any discussion or information contained in this bulletin serves as the receipt of, or as a substitute for, personalized investment advice from Arlington Hall Research & Investment Management, LLC. To the extent that a reader has any questions regarding the applicability of any specific issue discussed above to his/her individual situation, he/she is encouraged to consult with the professional advisor of his/her choosing.

Arlington Hall Research is NOT a tax advisor ora legal advisor.  Please consult your advisor for tax and legal advice.

BLOG DISCLAIMER: Due to the nature of the Internet, arlingtonhall.com does not make specific trading recommendations or give individualized market advice. Information contained in this publication is provided as an information service only. Arlingtonhall.com and Arlington Hall Research and Investment Management recommend that you get personal advice from an investment professional before buying or selling stocks or other securities. The securities markets and especially Internet stocks are highly speculative areas for investments and only you can determine what level of risk is appropriate for you. Also, readers should be aware that Arlington Hall Research & Investment Management, its employees and affiliates may own securities that are the subject of reports, reviews or analysis within this publication. We obtain the information reported herein from what it deems reliable sources; no warranty can be given as to the accuracy or completeness of any of the information provided or as to the results obtained by individuals using such information. Each user shall be responsible for the risks of their own investment activities and, in no event, shall Arlington Hall Research & Investment Management or its employees, agents, partners, or any other affiliated entity be liable for any direct, indirect, actual, special or consequential damages resulting from the use of the information provided. Under no circumstances does the information in this column represent a recommendation to buy or sell stocks. Arlingtonhall.com and Arlington Hall Research & Investment Management relies on information provided by corporations, news services, in-house research, published brokerage research, Edgar filings, and also may include information from outside sources and interviews conducted by ourselves. Readers should not rely solely on the information contained in this publication, but should consult with their own independent tax, legal, business and financial advisors with respect to any investment opportunity, including any contemplated investment in any security.

PRIVACY POLICY

In the course of client relationships, Arlington Hall Research & Management, LLC (“AHR”) gathers and maintains personal, non-public information regarding its clients’ financial circumstances and investment objectives. AHR is committed to maintaining the privacy and confidentiality of this client information. Accordingly, AHR has adopted a privacy policy in accordance with SEC and FTC privacy regulations which require investment advisers to determine and disclose how they treat nonpublic information about their clients and potential clients.

A. AHR may collect nonpublic personal information about AHR’s clients and potential clients from the following sources:

Information received from account applications, written questionnaires, interviews/conversations, information forms and other client interactions;

Information about transactions with AHR, any affiliates of AHR, or others; and

Information AHR obtains or receives from a consumer reporting agency.

All client information is to be maintained in AHR’s master client files and/or stored on appropriate electronic media. Information from potential clients may be filed in temporary files, but shall be subject to the same restrictions and limitations as other client files outlined below.

B. Adviser personnel are prohibited from sharing or disclosing nonpublic information regarding any client or potential client of AHR, except (i) as necessary to service client accounts including, without limitation, the settlement, billing, processing, clearing, or transferring of client transactions; or (ii) as otherwise directed by a client. Access to all client files and information, whether in paper or electronic format, is limited to Adviser
personnel for the purposes of servicing client accounts.

C. Adviser personnel may not remove client files or information from AHR’s premises unless (i) it is necessary to service client accounts; and (ii) prior approval is obtained from the Chief Compliance Officer.

D. All client files are secured at the end of each business day, and exterior doors always remain locked.

E. All computers are set up so they ‘lock’ when not in use, requiring a password to gain access.

F. Traffic flow in the office is restricted, and no individuals, other than employees, are allowed free access to areas where client information is held.

G. Employees working remotely must utilize passwords to gain access to the AHR system servers.

H. AHR will provide clients with a privacy notice (the “Privacy Notice”) when the client engages AHR for advisory or other services. The Privacy Notice details the types of nonpublic client information AHR collects, the information AHR shares with third parties or with affiliates, the kinds of third parties with which AHR shares information, the policies and practices AHR has in place to protect the confidentiality and security of nonpublic client information; the procedures AHR has in place to permit clients or potential clients to opt out of information sharing arrangements with third parties (inapplicable to AHR so long as AHR only shares information with third parties for purposes of servicing client accounts), and AHR’s disposal policy.

I.AHR shall deliver an updated Privacy Notice to all of its clients annually, even if the policy has not changed since the previous year. “Delivery” may, to the extent allowed by law, mean notification of the availability of the notice on a website.

J. Privacy Notices may be included in a quarterly report, newsletter or other client mailing. A copy of AHR’s current Privacy Notice is attached hereto.

K. AHR has undertaken to protect client information in the course of its disposal as well. All documents are electronically scanned into computer hard drives for the client files and then they are destroyed using an onsite shredder.

L. The Chief Compliance Officer is responsible for evaluating AHR’s compliance with this privacy policy on an ongoing basis.

Arlington Hall Research & Management, LLC
NOTICE OF PRIVACY POLICY

This is for your information only. No action is required on your part.

At Arlington Hall Research & Management, LLC, protecting your privacy is very important to us. We want you to understand what information we collect and how we use it. We collect and use “nonpublic private information” in order to provide our clients with a broad range of financial services as effectively and conveniently as possible. We treat nonpublic personal information in accordance with our privacy policy.

What Information We Collect and From Whom We Collect It

We may collect nonpublic personal information about you from the following sources:

Information we receive from you on applications or other forms;

Information about your transactions with us, our affiliates or others; and

Information we receive from non-affiliated third parties, including consumer reporting agencies.

“Nonpublic personal information” is nonpublic information about you that we obtain in connection with providing a financial service or product to you.

What Information We Disclose and To Whom We Disclose It

We do not disclose any nonpublic information about you without your express consent, except as permitted by law. This applies to current as well as former clients. We restrict access to your nonpublic personal information to those employees, affiliates and independent third parties who need to know that information in order to provide products or services to you. Our “affiliates” are companies with which we share common ownership. We do not currently have any affiliated companies.

Our Security Procedures

We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information. This includes measures to protect your information in the course of its disposal.

Updated February 2010