Privacy Principles

Like most industries today, the financial services industry is rapidly being shaped by
technology, which is literally changing the way we do business. To be successful in this
environment, we must continue to insure that our customers are confident that we will
manage their financial affairs expertly and confidentially.

At Guelich Capital Management LLC our customers have access to a broad range of
products and services from basic banking products to investments, mortgages, insurance, and online banking. To deliver these products and services as effectively and conveniently as possible, it is essential that we use technology to manage and maintain certain customer information.

We want to assure all of our customers that whenever information is used, it is done with discretion. The safeguarding of customer information is an issue we take seriously at Guelich Capital Management LLC. To affirm our continuing commitment to the proper use of customer information, we have set forth the following Privacy Principles. It is these Privacy Principles that guide us in serving the privacy needs of our customers.

1. Recognition of a Customer’s Expectation of Privacy: At Guelich Capital
Management LLC we believe the confidentiality and protection of customer information
is one of our fundamental responsibilities. And while information is critical to providing
quality service, we recognize that one of our most important assets is our customers’
trust. Thus, the safekeeping of customer information is a priority for Guelich Capital
Management LLC.

2. Use, Collection, and Retention of Customer Information: Guelich Capital
Management LLC limits the use, collection, and retention of customer information to
what we believe is necessary or useful to conduct our business, provide quality service,
and offer products, services, and other opportunities that may be of interest to our
customers. Information collected may include, but is not limited to: name, address,
telephone number, tax identification number, date of birth, employment status, annual
income and net worth.

3. Maintenance of Accurate Information: Guelich Capital Management LLC recognizes that it must maintain accurate customer records. Therefore, Guelich Capital
Management LLC has established procedures to maintain the accuracy of customer
information and to keep such information current and complete. These procedures
include responding to requests to correct inaccurate information in a timely manner.

4. Limiting Employee Access to Information: At Guelich Capital Management LLC
employee access to personally identifiable customer information is limited to those with
a business reason to know such information. Employees are educated on the
importance of maintaining the confidentiality of customer information and on these
Privacy Principles. Because of the importance of these issues, all Guelich Capital
Management LLC employees are responsible for maintaining the confidentiality of
customer information and employees who violate these Privacy Principles will be
subject to disciplinary measures.

5. Protection of Information via Established Security Procedures: Guelich Capital
Management LLC recognizes that a fundamental element of maintaining effective
customer privacy procedures is to provide reasonable protection against the
unauthorized access to customer information. Therefore, Guelich Capital Management
LLC has established appropriate security standards and procedures to guard against
any unauthorized access to customer information.

6. Restrictions on the Disclosure of Customer Information: Guelich Capital Management LLC does not disclose the nonpublic personal information we collect about our customers to anyone except: (i) in furtherance of our business relationship with them and then only to those persons necessary to effect the transactions and provide the services that they authorize (such as broker-dealers, custodians, independent managers etc.); (ii) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided by law.

We are permitted by law to disclose the nonpublic personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative services on our behalf). These third parties are prohibited to use or share the information for any other purpose. If you decide at some point to either terminate our services or become an inactive customer, we will continue to adhere to our privacy policy, as may be amended from time to time.

7. Disclosure of Privacy Principles to Customers: Guelich Capital Management LLC
recognizes and respects the privacy expectations of our customers. We want our
customers to understand our commitment to privacy in our use of customer information.
As a result of our commitment, we have developed these Privacy Principles that are
made readily available to our customers. Customers who have questions about these
Privacy Principles or have a question about the privacy of their customer information
should call Connie C. Guelich at 540-772-4545 or e-mail her at [email protected]
These Privacy Principles apply to individuals, and we reserve the right to change these
Privacy Principles, and any of the policies or procedures described above, at any time
without prior notice. These Privacy Principles are for general guidance and do not
constitute a contract or create legal rights and do not modify or amend any agreements we have with our customers.