Customer Privacy Policy Notice

In November of 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA). The GLBA requires
certain financial institutions, such as investment advisor firms, to protect the privacy of customer
information. In situations where a financial institution does disclose customer information to
non-affiliated third parties, other than permitted or required by law, customers must be given
the opportunity to opt out or prevent such disclosure. 103 Advisory Group does not share or
disclose customer information to non-affiliated third parties except as permitted or required by
law.

103 Advisory Group is committed to safeguarding the confidential information of its clients. 103
Advisory Group holds all personal information provided by clients in the strictest confidence and
it is the objective of 103 Advisory Group to protect the privacy of all clients. Except as permitted
or required by law, 103 Advisory Group does not share confidential information about clients
with non-affiliated parties. In the event that there were to be a change in this policy, 103 Advisory
Group will provide clients with written notice and clients will be provided an opportunity to direct
103 Advisory Group as to whether such disclosure is permissible.

To conduct regular business, 103 Advisory Group may collect personal information from sources
such as:

• Information reported by the client on applications or other forms the client provides to
  103 Advisory Group
• Information about the client’s transactions implemented by 103 Advisory Group or others
• Information developed as part of financial plans, analyses or investment advisory
  services

To administer, manage, service and provide related services for client accounts, it is necessary
for 103 Advisory Group to provide access to customer information within the firm and to nonaffiliated
companies, with whom 103 Advisory Group has entered into agreements. To provide
the utmost service, 103 Advisory Group may disclose the information below regarding customers
and former customers, as necessary, to companies to perform certain services on 103 Advisory
Group’s behalf.

• Information 103 Advisory Group receives from the client on applications (name, Social
  Security number, address, assets, etc.)
• Information about the client’s transactions with 103 Advisory Group or others (account
  information, payment history, parties to transactions, etc.)
• Information concerning investment advisory account transactions
• Information about a client’s financial products and services transaction with 103 Advisory
  Group

Since 103 Advisory Group shares non-public information solely to service client accounts, 103
Advisory Group does not disclose any non-public personal information about 103 Advisory
Group’s customers or former customers to anyone, except as permitted by law. However, 103
Advisory Group may also provide customer information outside of the firm as required by law,
such as to government entities, consumer reporting agencies or other third parties in response
to subpoenas. In the event that 103 Advisory Group has a change to its customer privacy policy
that would allow it to disclose non-public information not covered under applicable law, 103
Advisory Group will allow its clients the opportunity to opt out of such disclosure.