Client Privacy Policy*

Harloff Capital Management (HCM), Harloff Inc., an independent money management firm and registered investment advisor, is committed to safeguarding the confidential information of it’s clients. We hold all personal information provided to our firm in the strictest confidence. These records include all personal information that we collect from you in connection with any of the services provided by HCM. We have never disclosed information to nonaffiliated third parties, except as permitted by law, and do not anticipate such a change in firm policy, and we are prohibited under the law from doing so without advising you first. As you know, we use financial information that you provide to us to help you meet your personal financial goals while guarding against any real or perceived infringements of your rights of privacy. Our policy with respect to personal information about you is listed below.

• We limit employee and agent access to information only to those who have a business or professional need to know, and only to nonaffiliated parties as permitted by law. (For example, federal regulations permit us to share a limited amount of information about you with a custodian or brokerage firm in order to execute securities transactions on your behalf, or so that our firm can discuss your financial situation with your accountant or lawyer.)
• We maintain a secure office and computer environment to ensure that your information is not placed at unreasonable risk.
• The categories of nonpublic personal information that we collect from a client depend upon the scope of the client engagement. It may include information about your personal finances, information about transactions between you and third parties, and information from consumer reporting agencies.
• For unaffiliated third parties that require access to your personal information, consultants, and auditors, we also require strict confidentiality in our agreements with them and expect them to keep this information private. Federal and state regulators also may review firm records as permitted under law.
• We do not provide your personally identifiable information to mailing list vendors or solicitors for any purpose.
• Personally identifiable information about you will be maintained during the time you are a client, and for the required time thereafter that such records are required to be maintained by federal and state securities laws, and consistent with ethical consideration and professional responsibility.

* This statement is for compliance with the Gramm-Leach-Bliley Act of 1999.