CLARKE CAPITAL PRIVACY POLICY

 Clarke Capital Management, Inc. (“CCM”) is committed to protecting the financial privacy of our investors and clients. As a Commodity Trading Advisor and provider of managed futures account trading programs, we adhere to a strict privacy policy to protect the security and confidentiality of our client’s nonpublic personal information. The information we collect from you is restricted solely to that which is required by CCM to remain in compliance with the regulatory standards set forth by the governing bodies of the futures industry.

What non-public personal information about you do we collect?

 During the process of opening a new account, you are asked to provide us non-public personal information, such as: your age, home address and telephone number, employer, birth date, net worth, annual income, investment objectives, and prior investment experience.

 We also collect information about your transactions with us such as: your account balance and account activity, the size of your investment, and which of our trading programs you invest in.

How do we protect the security and confidentiality of the information you provide?

  We incorporate strict physical, electronic and procedural policies to safeguard your nonpublic personal information. Access to this information is limited only to those employees who require it during the course of conducting normal business. CCM employees are trained to handle your information properly and securely before being granted such access. Additionally, CCM employs in-house multi-level security methods to prevent unauthorized disclosure of nonpublic client information. 

 What nonpublic personal information do we disclose about you?

We do not disclose any nonpublic personal information to any affiliates or to non-affiliated third parties, except as necessary to serve our clients and/or fulfill ordinary business requirements. These may include (but are not limited to):

·         Account transaction processing and maintenance

·         Legal, Accounting, Regulatory or Audit agencies

·         Other business-related services, to the extent permitted by law.

It is CCM policy NOT to sell or market any public OR nonpublic client information.

 We are committed to ensuring the integrity of confidential client information. If CCM conducts business with a non-affiliated third party that requires dissemination of nonpublic personal client information, CCM will require said third party to be bound by CCM’s privacy policy before any business is conducted, or information is released.

How does this Privacy Policy affect former CCM clients?

  In the event that a client terminates his/her relationship with CCM, our privacy policy remains in full effect as described above.

Investor privacy is a cornerstone of the relationship that Clarke Capital Management maintains with our clients. If you have any questions regarding this policy, please contact us at (630) 323-7033. Clarke Capital Management reserves the right to change this privacy policy, as permitted by law. We will notify clients of any such changes, in writing, as required by law.

This notice is updated and provided to all clients annually via a quarterly statement mailing to comply with futures industry regulations. Additionally, it is provided to new clients as part of the CCM Account Opening package, available from the documents page.

Past results are not necessarily indicative of future results.