PRIVACY POLICY

Registrant does not release personal information on its clients to any unaffiliated third parties other than those requested by registrant's clients (i.e. accountants, business managers, lending institutions, etc.), as required by law, or to those who have a business reason in order to service clients. Registrant does not sell customer information or share it with organizations outside of Winans Investments.

Registrant collects nonpublic personal information about you from the following sources: Information we receive from you on applications or other forms; Information about your transactions with us; or others and, Information we receive from brokerage firms.

Registrant does not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law.

Registrant has physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information. We continually review our policies and practices and monitor our computer networks in order to help us secure the safety of your customer information.

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