H. Rivkin & Co. ("HRCO") respects your right to privacy. We have always been committed to secure the confidentiality and integrity of your personal information. We are proud of our privacy practices and want our current and prospective clients to understand what information we collect and how we use it.

Why We Collect Your Information

We gather information about you and your accounts so that we can (i) know who you are and thereby prevent unauthorized access to your information, (ii) design and improve the products and services we offer and (iii) comply with the laws and regulations that govern us.

What Information We Collect

We may collect the following types of "nonpublic personal information" about you:
- Information about your identity, such as your name, address and social security number;
- Information about your transactions with us;
- Information we receive from your on applications, such as your finances and employment.

What Sources We Obtain Your Information

We collect nonpublic information about HRCO clients such as you from the following sources:
- Information we receive from you on applications or other forms;
- Information about your transactions with us, or others; and
- If applicable, information we receive from a risk management firm.

What Information We Disclose

Your securities account is carried by our clearing firm pursuant to a clearing agreement. We may disclose all the information we collect regarding your account. Our clearing firm is contractually obligated to keep the information that we provide them confidential and use the information only for the services required and as allowed by applicable law or regulation.

We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law and noted above. Moreover, we will not release information about our customers or former customers, except as noted above unless one of the following conditions is met:

- We receive your prior written consent.
- We believe the recipient to be you or your authorized representative.
- We are required by law to release information to the recipient.

We only use the information about you and your account to help us better serve your investment needs or suggest services or educational materials that may be of interest to you.

Confidentiality And Security

We maintain physical, electronic and procedural safeguards to guard your personal account information. We also restrict access to your personal and financial data to authorized HRCO associates who have a need for these records. We require all nonaffiliated organizations to conform to our privacy standards and are contractually obligated to keep information provided confidential and used as requested. Furthermore, we will continue to adhere to the privacy policies and practices described in this notice even after your account is closed or becomes inactive.

We will continue to conduct our business in a manner that conforms with our pledge to you, your expectations and all applicable laws.