The following information contains the privacy policy of Sturdivant & Co. (the “Firm”) designed to protect the confidentiality of current or former customers (“you”) of the Firm.

        Your nonpublic personal information: The Firm does not sell your nonpublic personal information. No client information is made available to any third party for the purpose of solicitation. We will only disclose your nonpublic personal information, which includes any personally identifiable information about you, as indicated in this policy if we have obtained your consent or we are required by law to disclose such information. (Nonpublic personal information collected includes information from you; about your transactions with us; about your transactions with nonaffiliated third parties and information from a consumer-reporting agency.)

        We restrict access to confidential personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards to comply with federal standards to guard your confidential personal information.

        All written materials containing client information are kept on-site in locked file cabinets. Only authorized employees of the Firm have access to client information and files. Outdated and redundant documentation is destroyed/shredded prior to disposal. This may include, but is not limited to, duplicate brokerage statements, tax-forms, letters, and notes.

        We maintain a secure local area computer network. This network is connected to the Internet by a secure firewall. Only properly encrypted computers can gain access to the network through the firewall. The network is physically stored on the local premise and only Firm personnel have access to the equipment. To avoid computer viruses, the entire network is scanned on a regular basis.

        Permitted Disclosure of Nonpublic Personal Information: In the ordinary course of providing financial services for your account, nonpublic personal information is disclosed to nonaffiliated third parties as required by law or with your authorization. In addition, we may disclose the information we collect to financial institutions with whom we have a joint marketing agreement.

        A “joint marketer” is a person or company who markets products or services under a joint agreement with one or more financial institutions. A “service provider” is a person or company who assists the Firm in administering, processing, or servicing a customer’s account.

        Affiliates and nonaffiliated third parties to whom we disclose: The Firm does not disclose any nonpublic personal information about you except as permitted by law or with your authorization.

        During the course of normal business, client information is shared with certain affiliates and nonaffiliated third parties. First, limited information is shared with the clients’ clearing firm, Apex Clearing Corporation. Second, client information may be viewed by government agencies during routine FINRA or SEC examinations, or when required by law. Third, limited client information may be viewed by a CPA firm hired by the Firm to audit books and records. All of these entities are required to follow strict confidentiality guidelines and can only use client data for the purpose of conducting normal operations.

        The Firm may form a strategic relationship with certain mutual fund, annuity or other product providers. As part of these relationships, we may receive compensation in excess of that disclosed in the products prospectus. The Firm does not mandate any specific sales goals for products offered by these providers, nor does the Firm penalize registered representatives for offering products of a provider who does not maintain a strategic relationship with the Firm. If you would like more information, please contact us.

        If you prefer that we not disclose confidential personal information about you to non-affiliated third parties not in connection with our normal business operations, you may opt out of those disclosures; that is, you may direct us not to make those disclosures (other than disclosures permitted by law). If you wish to opt out of disclosures to non-affiliated third parties, you may inform us by the following means: (a) e-mail Mr. Harvey deKrafft at hdekrafft@sturdivant-co.com; (b) call the following telephone number between 9AM and 4:30PM (EST): (856) 751-1331 and ask for Mr. deKrafft; or (c) send a written note via fax to (856) 751-1141, to the attention of Mr. deKrafft.

        There are no opt out rights for any disclosures of nonpublic personal information that the Firm may make to service providers or joint marketers, but the Firm will disclose the nature of any information to be shared with a service provider or joint marketer and must enter into contractual arrangements to require the third party to maintain confidentiality of your information

        The opt-out rights also do not apply to disclosure of confidential information in the following circumstances:

        •        When you have consented to, and has not revoked, the disclosure;
        •        For resolving customer disputes or inquiries;
        •        To persons holding a legal or beneficial interest relating to you;
        •        To persons acting in a fiduciary or representative capacity on your behalf;
        •        To provide information to agencies assessing the Firm’s compliance with industry standards, and to your attorneys, accountants, and auditors;
        •        In connection with a proposed or actual sale or merger of the Firm;
        •        To respond to a regulator’s examination of the Firm; or
        •        To comply with a civil, criminal, or regulatory investigation by federal, state, or local authorities.

        Since no information is disclosed to third parties except as stated above, by default, all clients have “opted out”.

        Former customers: The Firm will only disclose nonpublic personal information about former customers as required by law or with your authorization. The Firm regularly revises and updates its information security program to keep pace with changes in technology.

        The Firm, in association with our clearing firm does offer customers the option to limit the sharing of information with other financial institutions. If you would like to request that your information not be shared with other financial institutions, or if you would like more information about the Firm’s and/or our Clearing Firm’s Privacy Policy, please notify us in writing.