This Privacy Policy Notice (the "Notice") covers the policies and practices of Vega Capital Group LLC (“Vega Capital Group”).

Protecting Your Privacy

Vega Capital Group recognizes that safeguarding personal and financial information about our clients is an essential commitment that we make and trust we hold. In this regard, we have adopted certain policies and procedures concerning the use of personal and financial information we collect about our clients. These policies and procedures govern the activities of our officers, directors and employees and strictly limit our ability to use or distribute personal and financial information about you. This Notice outlines those policies and procedures.

Collection of Information

We may receive personal and financial information about you from the following sources:

• Information you provide us on applications or other forms or which may be publicly available (this includes your name, address, social security number, assets and income);
• Information you direct or authorize us to obtain from third parties such as advisers or custodians (including investment, legal, insurance or other financial advisers, or brokerage houses, banks or asset custodians);
• Information you give us orally; and
• Information about your financial transactions with us (such as your account balance, payments history) or others.

We do not disclose any personal or financial information about our clients or former clients without their authorization or direction, except as disclosed below.

Information sharing with unaffiliated Third Parties as Permitted by Law

From time to time, we may provide information to third parties (such as brokers, other financial, legal, insurance or investment advisers, or custodians) to complete a transaction you have requested, to help us service your account or as specifically directed by you or your agent. However, any such disclosure not specifically requested by you will only be as permitted by law and only as reasonably necessary for Vega Capital Group or such third parties to provide the agreed services to you. All companies with whom we do business are contractually obligated to comply with strict standards regarding security and confidentiality, and the information can be used only for the sole purpose of providing the service we have requested the company to perform.

Sharing Information in Other Situations

We may also disclose information about you as required by law, such as when we respond to subpoena or other legal process or reporting to a credit bureau. When responding to a subpoena or other legal process, we will provide you with any required notice and, whenever practicable, we will discuss our response with you.

Keeping Information Safe and Accurate

We limit access to information we have about you to those employees who have a reasonable need to know to provide you with services to help you meet your financial needs. We maintain physical, electronic and procedural internal safeguards that comply with federal laws and regulations to guard the information we have about you.

An Ongoing Commitment to Your Privacy

We are just as committed to protecting the privacy of our former clients as we are of our current clients. If you choose to end your relationship with us, you will continue to be protected by the privacy policies and principles described in this policy or any future amendments to this policy.

Other Ways to Protect Your Privacy

There are several things you can do to protect yourself and your family from identity theft and related crimes. Helpful tips can be found on the Federal Trade Commission’s Identity Theft website at http://www.ftc.gov/bcp/edu/microsites/idtheft/index.html or by calling 1-877-IDTHEFT. This website also provides you with important information on what you should do if you believe you are a victim of identity theft. If you have been a victim of identity theft, please contact us immediately so we can assist you with any issues related to your accounts with Vega Capital Group.

This Notice does not expand legal obligations. This Notice is not intended to create any liability other than that already found in the law. This notice is effective as of March 31, 2012. There have been no significant changes to the policy since March 31, 2011. To review the most current version of our privacy policy, please visit our website at http://www.vegacapital.com/legal.php and click on the link for "Privacy Policy".