Latest update: April 9, 2014

The following information details how we use and protect your personal information. Please read this Privacy Policy carefully.

Venovate Advisors, LLC (“Venovate Advisors”) is committed to maintaining the confidentiality, integrity and security of the personal information that is entrusted to us. We respect your right to keep your personal information confidential and understand your desire to avoid unwanted solicitations. We hope that by taking a few moments to review this policy, you will have a better understanding of what we do with the information you provide us.

Venovate Advisors generally does not disclose personal information about our clients or former clients to anyone. We do disclose personal information about or clients with client authorization. Except as otherwise described in this notice we restrict access to nonpublic personal information about you to employees of our firm and other parties who must use that information to provide services to you such as Broker-dealers who hold client assets, and our sub-advisors who help manage those assets.

The categories of nonpublic information that we collect from you may include information about your personal finances, information about your health to the extent that it is needed for the financial planning process, information about transactions between you and third parties, and information from consumer reporting agencies, e.g., credit reports. We use this information to help you meet your personal financial goals.

With your permission, we disclose limited information to attorneys, accountants, and mortgage lenders with whom you have established a relationship. You may opt out from our sharing information with these nonaffiliated third parties by notifying us at any time by telephone, mail, fax, email, or in person. With your permission, we share a limited amount of information about you with your brokerage firm and our sub-advisor, Loring Ward, in order to execute securities transactions on your behalf.

We maintain a secure office to ensure that your information is not placed at unreasonable risk. We employ a firewall barrier, secure data encryption techniques and authentication procedures in our computer environment.

We do not provide your personal information to mailing list vendors or solicitors. We require strict confidentiality in our agreements with unaffiliated third parties that require access to your personal information, including financial service companies, consultants, and auditors. Federal and state securities regulators may review our Company records and your personal records as permitted by law.

Personally identifiable information about you will be maintained while you are a client, and for the required period thereafter that records are required to be maintained by federal and state securities laws. After that time, information may be destroyed.

We comply with the USA Patriot Act Section 326. Please read this important information about procedures for opening a new account. To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. When you open an account, we will ask for your name, address, date of birth (for individuals), and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents.

We may disclose certain nonpublic information about you for the following reasons:

To comply with the validly issued and enforceable subpoena or summons.

In the event of a prospective purchase, sale, merger, provided that we take appropriate precautions (for example, through a written confidentiality agreement) so the prospective purchaser or merger partner does not disclose information obtained in the course of the review.

We may disclose information we have about clients as permitted by law. For example, we may share information with regulatory authorities and law enforcement officials who have jurisdiction over us or if we are required to do so by applicable law and provide information to protect against fraud.

As a part of any actual or threatened legal proceedings or alternative dispute resolution proceedings either initiated by or against us, provided we disclose only the only information necessary to file, pursue, or defend against the lawsuit and take reasonable precautions to ensure that the information disclosed does not become a matter of public record.

Federal law requires us, and other financial institutions to disclose our Privacy Policy, and to deliver this Privacy Notice to you annually, in writing. The most current version of this policy is always available on the Venovate Advisors website. We will notify you in advance if our privacy policy is expected to change.