Performance Tracking Inc. (PTI) recognizes that clients expect their personal information to be handled in a confidential manner and have, therefore, adopted the following policies to safeguard their privacy and to explain the circumstances under which we may collect, maintain, and use any non-public personally identifiable information that they may provide to us. We collect information to help us and our custodian firm(s) perform our duty as a registered investment advisor and to fulfill applicable legal and regulatory requirements. The type of information we gather may include the following: Information we receive on account opening applications or other forms, such as a client’s name, address, social security number, employment and marital status, beneficiary designations (if applicable) income and liquid asset value. Information about transactions with us, such as account balances, correspondence with us, and payment history. We do not share any non-public personal information with unaffiliated third parties unless 1. The client gives us written permission; 2. It is necessary to process an account application or service the account(s) or otherwise complete a transaction on a client’s behalf; 3. It is necessary to protect against fraud or to comply with a subpoena or other court order; or 4. It is otherwise required or permitted by law or regulation. However, we do provide information to our custodian firm(s) or broker dealer(s), who have adopted similar privacy policies, government or regulatory agencies and certain service providers. These companies and agencies are not permitted to use or share this information for any purpose and will also maintain such information as confidential. We do not disclose any non-public, personal information to any outside unaffiliated company, except as permitted by law or as needed to service the account. Furthermore, we maintain physical, electronic, and procedural safeguards to protect non-public information.