1. Information Collected

In order to access certain products, services and areas (collectively, the “Services”) within Hixon Zuercher Capital Management’s web site located at the uniform resource locator www.hzcapital.com (collectively, the “Web Site”), Hixon Zuercher Capital Management, require that you provide certain identifying information (the “Registration Data”) listed in the online Client’s Only Registration page or other pages within the Web Site. This information may include your legal name, address, alternative address, phone number, e-mail address, subscriber name or “screen name,” ownership information of services and products sold by HIXON ZUERCHER CAPITAL MANAGEMENT or of financial portfolio holdings, areas of interest, and password used to access the Services. HIXON ZUERCHER CAPITAL MANAGEMENT reserves the right to request any additional information necessary to establish and maintain your account for use of any of the Services available on the Web Site.

HIXON ZUERCHER CAPITAL MANAGEMENT places Internet “cookies” on your computer’s hard drive solely for session information, including information needed to navigate in and around the Web Site. Once your browser is closed, the session cookie is not saved.

2. Confidentiality

Registration Data is the property of HIXON ZUERCHER CAPITAL MANAGEMENT, subject to and protected by applicable laws. Unless otherwise authorized as part of your Client Registration or as a part of your experience on the Web Site, HIXON ZUERCHER CAPITAL MANAGEMENT will not sell, rent, swap or otherwise disclose your Registration Data to any third party. Client account information is accessible only by authorized personnel.

3. Uses Of Registration and Other Data

HIXON ZUERCHER CAPITAL MANAGEMENT reserves the right to disclose to third parties information about your usage of the Web Site and any related services, including information gathered during your use of the Web Site. Any third party to which HIXON ZUERCHER CAPITAL MANAGEMENT rents, sells, shares or otherwise discloses personal data will be carefully pre-screened by HIXON ZUERCHER CAPITAL MANAGEMENT, determined by HIXON ZUERCHER CAPITAL MANAGEMENT to be reputable, and will use the personal data for marketing products and services which HIXON ZUERCHER CAPITAL MANAGEMENT determines, in its sole judgment, that you might find of interest. Unless authorized by you as a part of your Client Registration or as a part of your experience on the Web Site, HIXON ZUERCHER CAPITAL MANAGEMENT will disclose such information to third parties only in the form of aggregate data (such as overall patterns or demographic reports) that does not describe or identify any individual user.

In addition, personal data collected by HIXON ZUERCHER CAPITAL MANAGEMENT will be used by HIXON ZUERCHER CAPITAL MANAGEMENT for editorial and feedback purposes, for marketing and promotional purposes, for a statistical analysis of your behavior while using the Web Site, for product development, for content improvement, to inform advertisers as to how many visitors have seen or clicked on their advertisements, and to customize content and layout of the Web Site. Names, postal and e-mail addresses collected may be added to HIXON ZUERCHER CAPITAL MANAGEMENT’s databases and used for future communications and mailings regarding Web Site updates, new products and services, upcoming events, and status of orders placed online.

HIXON ZUERCHER CAPITAL MANAGEMENT does not currently accept any information submitted to or posted at its Web Site from children under the age of 13. No information should be submitted to or posted at the Web Site by children under 13 years of age without the consent of their parent or legal guardian. HIXON ZUERCHER CAPITAL MANAGEMENT does not allow children under 13 to register as clients or to receive direct marketing communications arising from their use of the Web Site and, therefore, HIXON ZUERCHER CAPITAL MANAGEMENT does not provide any personally identifiable information from children under 13 to any third party. HIXON ZUERCHER CAPITAL MANAGEMENT does encourage parents and guardians to spend time online with their children and to participate in the interactive activities offered on the Web Site.

4. HIXON ZUERCHER CAPITAL MANAGEMENT’s Right to Contact You

HIXON ZUERCHER CAPITAL MANAGEMENT reserves the right to contact visitors to the Web Site regarding account status and changes to the Terms and Conditions of Use, Privacy Policy, or any other policies or agreements relevant to visitors or users of the Web Site.

5. User Access to Information Collected

The Client Web Portal link and related information is password-restricted for your protection. You may change your password by contacting our Client Service Coordinator.

6. Lost or Stolen Password

If your password is lost or stolen, you should immediately notify our Client Service Coordinator by writing them at 101 West Sandusky Street, Suite 301, Findlay, OH 45840 or calling them at (419) 425-2400.

7. Cancellation

You can cancel or close your access to the Client Web Portal site and your HIXON ZUERCHER CAPITAL MANAGEMENT Reports at any time by writing or calling our Client Service Coordinator. Your notice becomes effective when received by HIXON ZUERCHER CAPITAL MANAGEMENT. You should include all requested information you may have with your notice.

8. No Liability for Acts of Third Parties

Although HIXON ZUERCHER CAPITAL MANAGEMENT will use all reasonable efforts to safeguard the confidentiality of the Registration Data, transmissions made by means of the Internet cannot be made absolutely secure. HIXON ZUERCHER CAPITAL MANAGEMENT will have no liability for disclosure of Registration Data due to errors in transmission, unauthorized acts of third parties or through the use of third party cookies including those of advertisers when you view or click on their advertisements. Once you leave the Web Site, you will be subject to third party privacy policies, which may differ significantly from our Privacy Policy.

9. Updates

HIXON ZUERCHER CAPITAL MANAGEMENT reserves the right to change or update this Privacy Policy, or any other HIXON ZUERCHER CAPITAL MANAGEMENT policy or practice, at any time. Any changes or updates will be effective immediately upon posting to the Web Site, and your use of the Web Site following such posting constitutes your acceptance of the Privacy Policy as so changed or updated.