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Structured Portfolio Management, LLC takes precautions to maintain the privacy of personal information concerning its current and prospective customers. These precautions include the adoption of certain procedures designed to maintain and secure such customer's nonpublic personal information from inappropriate disclosure to third parties. Federal regulations require us to inform customers of this privacy policy.
We collect nonpublic information about our customers from the following sources:

• Information we receive from a customer in documents in forms we may supply;
• Information about a customer's transactions with us, our affiliates, or others; and
• Information we may receive from a consumer reporting agency.

We do not disclose any nonpublic personal information about our prospective, existing or former customers to anyone, except as permitted by law and regulation.
We restrict access to nonpublic personal information about customers to those employees and agents of Structured Portfolio Management, LLC who need to know that information in order to provide services to its customers. We may also disclose such information to our affiliates and to service providers and financial institutions that provide services to us. We require such third party service providers and financial institutions to protect the confidentiality of our customers' nonpublic personal information and to use the information only for purposes for which it is disclosed to them. We maintain physical, electronic, and procedural safeguards that comply with federal standards to safeguard customers' nonpublic personal information and which we believe are adequate to prevent unauthorized disclosure of such information.