Cullen Cioffi Capital Management, LLC (“Cullen Cioffi Capital Management”, “firm”, “we”, or “our”), as a Registered Investment Adviser, is covered under the definition of a “financial institution” under the Gramm-Leach-Bliley Act and the Securities and Exchange Commission’s (“SEC”) Privacy of Consumer Financial Information Rule (“Regulation S-P”).

The staff of Cullen Cioffi Capital Management realizes that providing personal information is an act of trust. Cullen Cioffi Capital Management values its clients’ trust and confidence. We will never sell or share the nonpublic personal information obtained from or in reference to clients. All information provided by clients to Cullen Cioffi Capital Management and its staff, and information and advice furnished to clients by us, shall be treated as confidential and shall not be disclosed to affiliated or unaffiliated third parties, except as permitted or directed by clients with written authorization, by application to facilitate the investment services offered by the firm via an unaffiliated financial services provider, or as required by any rule, regulation or law.

Commitment to Your Private Information. Cullen Cioffi Capital Management is committed to safeguarding the confidential information of its clients. Cullen Cioffi Capital Management holds all personal information provided by clients in the strictest confidence and it is the objective of the firm to protect the privacy of all clients. Except as permitted or required by law, Cullen Cioffi Capital Management does not share confidential information about clients with non-affiliated parties. It is our policy to restrict access to all current and former clients' information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/non-affiliated entities who need to know that information in order to provide products or services in furtherance of the client's engagement of Cullen Cioffi Capital Management. Cullen Cioffi Capital Management permits only authorized employees and affiliates who have acknowledged receipt and understanding of our Privacy Policy (by acknowledging and accepting our firm’s Compliance Policies and Procedures) to have access to client information. Employees violating Cullen Cioffi Capital Management’s Privacy Policy will be subject to our disciplinary process. If there are any changes to this policy, we will provide clients with written notice and clients will be provided an opportunity to direct Cullen Cioffi Capital Management as to whether such changes are permissible.
 

Why We Collect and How We Use Information. To conduct regular business, Cullen Cioffi Capital Management may collect personal information from sources such as:

• Information reported by the client on applications or other forms the client provides to the firm

• Information about the client’s transactions implemented by the firm or others

• Information developed as part of financial plans, analyses, or investment advisory services

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To administer, manage, service, and provide related services for client accounts, it is necessary for Cullen Cioffi Capital Management to provide access to client information within the firm and to non-affiliated companies, with whom we have entered into agreements.

The disclosure of information contained in any document completed by the client for processing and/or transmittal by Cullen Cioffi Capital Management to facilitate the commencement/continuation/termination of a business relationship between the client and/or between Cullen Cioffi Capital Management and a non-affiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, record keeper, insurance company, etc.), including, but not limited to, information contained in any document completed and/or executed by the client in furtherance of the client's engagement of Cullen Cioffi Capital Management (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding non-affiliated third-party service provider.

Sharing Information with Other Companies Permitted Under Law. Cullen Cioffi Capital Management may disclose the client's information: (1) to individuals and/or entities not affiliated with Cullen Cioffi Capital Management, including, but not limited to the client's other professional advisors and/or certain service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, record keeper, proxy management service provider, etc.) that may be recommended or engaged by Cullen Cioffi Capital Management in furtherance of the client's engagement of Cullen Cioffi Capital Management; (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. Since Cullen Cioffi Capital Management shares nonpublic information solely to service client accounts, the firm does not disclose any nonpublic personal information about the firm’s customers or former customers to anyone, except as permitted by law. In the
event that the firm has a change to its client privacy policy that would allow it to disclose non-public information not covered under applicable law, the firm will allow its clients the opportunity to opt out of such disclosure. Finally, Cullen Cioffi Capital Management strives to only recommend financial services providers that share its privacy policies; however, clients are encouraged to request each specific firm’s written policy for review.

Information Security. Cullen Cioffi Capital Management maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients' nonpublic personal information. Through this policy and its underlying procedures, Cullen Cioffi Capital Management attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information. Cullen Cioffi Capital Management maintains client records in a controlled environment and records are only available to authorized persons of the firm who have a need to access client information in order to deliver advisory services or respond to client requests. Cullen Cioffi Capital Management’s policy to protect client information extends beyond the termination of the Engagement Letter or Client Agreement.
Children. Our company website is not directed to children under the age of 18 years. By accessing and using our website, you represent and warrant that you are at least 18 years old.

Former Clients. Even if we cease to provide you with financial products or services, our Privacy Policy will continue to apply to you, and we will continue to treat your nonpublic information with strict confidentiality.

Changes to this Policy. Cullen Cioffi Capital Management will provide each client with initial notice of the firm's current privacy policy when the client relationship is established. We will also provide each client with a new notice of the firm’s current privacy policy at least annually. If, at any time, Cullen Cioffi Capital Management adopts material changes to its privacy practices, the firm shall provide each client with a revised notice reflecting the new privacy practices.

Contact Us: Clients are encouraged to discuss any questions regarding privacy policies and procedures directly with Ryan G. Cullen, Chief Compliance Officer of Cullen Cioffi Capital Management. Contact information: ryan@cullencioffi.com or 513-508-3183.

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