This privacy policy explains the manner in which Kerford (sometimes referred to herein as "we," "us," or "our") collects, utilizes and maintains nonpublic personal information about its customers and those parties with whom Kerford has a prospective relationship (sometimes referred to herein as "you" or "your"). This policy only applies to nonpublic personal information of individuals (not entities).

Nonpublic Personal Information Collected – We collect nonpublic personal information when you (a) open and maintain an account with us or (b) inquire as to a financial product or service offered by us. Specifically, we collect nonpublic personal information from the following sources:

- From account opening documents and any other forms delivered by you to us (such as name, address, social security number or tax identification number, assets, and income);

- From transactions made by or with us (including account balances, and cash deposits/withdrawals);

- From entities outside of Kerford (e.g., information obtained from credit rating agencies);

- From visits to an Kerford site (cookies may be used to track your activities while on a web site, although cookies do not contain personal information about you unless you knowingly provide it); and

- From any direct inquiry regarding an Kerford product or financial service (such as use of the Kerford Online Trading System).

Sharing of Nonpublic Personal Information – We do not sell or rent customer information. We do not disclose nonpublic personal information about customers (current or former) to any nonaffiliated third parties or to affiliated entities, except as permitted by law. Such instances where information may be shared include:

- To service providers in connection with the administration and servicing of an account, which may include attorneys, accountants, auditors and other professionals;

- To affiliated companies in order to provide you with ongoing personal advice and assistance with respect to the products and services you have purchased through us and to introduce you to other products and services that may be of value to you;

- To respond to a subpoena or court order, judicial process or to regulatory authorities; and

- To protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities.

If you are a consumer and not a customer of Kerford Investment, we may share some or all of your personal information with entities not affiliated with us as permitted by law. Please be advised, however, that we only share such information with service providers that market our products or services. Further, the information provided does not include credit information, such as credit history, net worth, or income information.

The law allows you to "opt out" of our sharing nonpublic personal information about you in certain circumstances with affiliated and nonaffiliated companies; that is, you may direct Kerford Investments to not make such disclosures. We do not currently share information about you with any affiliate or third party that triggers this opt out right. Therefore, there is no need for you to opt out. If in the future we desire to disclose your information in a way that is inconsistent with this policy, we will notify you in advance and provide you with the opportunity to opt out of such disclosure.

Security Technology – We protect your account information by placing it on the secure portion of the Kerford’s web site, using various tools such as firewalls and data encryption, and requiring you to enter a unique username and password to access your account information online. With respect to internal security procedures, we restrict access to nonpublic personal information to those officers or employees who need to know that information to perform services to our customers. At Kerford, we value the protection of our customers' nonpublic personal information and will continue to do our best in making sure you feel confident that our information safeguards satisfy your needs.

Changes In The Privacy Policy – We may make changes to our privacy policy in the future. We will not make any change affecting you without first sending you a revised privacy policy describing the change. In any case, we will send customers a current privacy policy at least once a year as long as such person is a customer.

Updating Your Nonpublic Personal Information – We work hard to keep complete and accurate information about you and your accounts. If you ever believe that our records are incorrect or incomplete, please let us know. We will investigate and correct any inaccuracies as quickly as possible. You may also update this information by contacting us through e-mail address provided below. When writing, please include your name, mailing address, telephone number and, if possible, your account number.

Questions – Should you have any questions regarding our privacy policy, please contact us through your respective Introducing Agents or the Kerford’s compliance department; all e-mail inquiries should be directed to compliance@kerfordfx.com