NOTICE OF INTEROCEAN FINANCIAL GROUP CLIENT PRIVACY POLICY

Our Commitment to Your Privacy: InterOcean Financial Group has a long-standing policy of protecting the confidentiality and security of information we collect about our clients. We do not share nonpublic personal information about you ("Information") outside of the InterOcean Financial Group family without your consent except for the specific purposes described below, in accordance with all applicable laws. This Notice describes the Information we may gather and the circumstances under which we may share it.
Why We Collect and How We Use Information: We limit the collection and use of Information to the minimum we require to deliver superior service to you. Such service includes advising you about our products, services and other opportunities, maintaining your accounts, through your custodian, processing transactions requested by you or other persons authorized by you and administering our business.

How We Gather Information: We get most Information directly from you or your agents, when you apply for, access and use our and our business partners' financial products and services - whether in person, by telephone or electronically. We may verify this information or get additional information from consumer reporting agencies or other sources. This Information may relate to your finances, employment, or other personal characteristics, such as your first and last name, address, phone number, social security number and email address, as well as accounts with us and transactions and interactions by us, with us, through us, or with others. We may also collect information about what you have entered into, viewed on and/or downloaded from our website.

How We Protect Information: Our employees, registered representatives and investment adviser representatives acting on our behalf are required to protect the confidentiality of Information and to comply with our established policies. They may access Information only when there is an appropriate reason to do so, such as to administer or offer our products or services. It is also InterOcean Financial Group’s policy to require all of our service providers (other than our affiliates) that are to receive any Information to sign strict confidentiality agreements. In addition, we maintain physical, electronic and procedural safeguards to protect Information, which comply with all applicable laws. Employees who violate our Privacy Policy are subject to disciplinary process.

Disclosure of Information: We may disclose any kind of Information when we believe it necessary for the conduct of our business, or where disclosure is required by law. For example, Information may be disclosed for audit or research purposes, to attorneys or other professionals, or to law enforcement and regulatory agencies to help, among other things, prevent fraud or money laundering. In addition, we may disclose any kind of Information to other InterOcean Financial Group companies or third party service providers (i) to enable them to provide business services for us, such as performing computer related or data maintenance or processing services for us, (ii) to facilitate the processing of transactions requested by you, (iii) to assist us in offering our or other InterOcean Financial Group companies' products and services to you, or (iv) for credit review or reporting purposes. We may also provide any kind of Information to other InterOcean Financial Group companies to enable us to offer you their products or services. Except in those specific, limited situations, without your consent, we will not make any disclosures of Information to other companies who may want to sell their products or services to you. For example, we do not sell customer lists and we will not sell your name to a catalogue company or telemarketer.

Our Former Clients: Even if you are no longer an InterOcean Financial Group client, our Privacy Policy will continue to apply to you.

To Whom This Policy Applies: This Privacy Policy applies for InterOcean Financial Group LLC, and the other members of the InterOcean corporate family, including but not limited to, InterOcean Financial Group LLC, InterOcean Securities LLC, InterOcean Equity Partners LLC, InterOcean Financial Advisors LLC, InterOcean Insurance Group LLC and all funds managed or administered by any of the foregoing, all of which are referred to collectively in this Notice as "InterOcean Financial Group" - except to the extent that in special circumstances any member of the InterOcean Financial Group corporate family has a special policy and sends notice of that policy to its clients who are affected by the special policy. This Privacy Policy applies to individuals to whom products or services are provided by InterOcean Financial Group offices in the United States, provided such products or services are used primarily for personal, family, or household purposes (not business purposes), whether or not the individuals have a customer relationship with us.
Access to and Correction of Information: Upon your written request, we will make available for your review any file we may maintain for your Information. However, information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available to you. If you notify us that any Information is incorrect, we will review it. If we agree, we will correct our records. If we do not agree, you may submit a short statement of dispute, which we will include in any future disclosure of the disputed Information.
Further Information: We reserve the right to change this Privacy Policy at any time. The examples contained within this Privacy Policy are illustrations and are not intended to be exclusive. If there are material changes to this policy they will be posted on our external website. This notice complies with Federal law, State law and SEC regulations regarding privacy. You may have additional rights under other foreign or domestic laws that may apply to you.

version dated 05/01/2006