Rand & Assiciates LLC -- Privacy Policy

• This notice summarizes our policy regarding the confidentiality and disclosure of client information. We understand that confidentiality of your personal nonpublic client information is critical to you and we regard the protection of your personal client information as one of our most important responsibilities.

Specifically, industry regulations require each member of the financial services industry to communicate its privacy policy to consumers at the time of establishing a customer relationship. We will reaffirm this policy annually in writing, for as long as you maintain a relationship with us.

At Rand & Associates we are committed to protecting the privacy and security of the information you share with us. You trust us with your personal and financial information, and we will honor that trust by handling your information carefully and sensibly. We do not sell your personal information to anyone. This notice will help you understand the types of personal information we maintain and how we use and safeguard your information.

We collect nonpublic, personal information about you from the following sources: information we receive from you on account applications or other forms; information from 3rd party data services (for example, to verify client identity); and information about your transactions with us and our affiliates, which we obtain in the process of servicing your account.

Over the life of your account, we gather information about your account holdings and the transactions that you make. We use this information to maintain accurate balance information, to help us provide efficient client services and to assist us in identifying investments or services that may be of value to you.

When you open an account, we may ask for non-transactional information that can include your income and investments, your financial goals and other similar information.

We do not disclose any nonpublic, personal information about our current or former clients to anyone, except as follows: (1) when it is legally required (such as in response to a subpoena); (2) to prevent fraud; (3) to comply with a legally permitted inquiry by a government agency or regulator; (4) among Rand & Associates owners and employees; or (5) service providers (for example, securities clearing houses).

Rand & Associates continually updates and monitors its security standards and procedures to help protect against anyone gaining unauthorized access to your confidential information. We continually research new technology to further enhance the security of your information. Additionally, we build checks and balances into procedures, such as occasionally asking you for information only you would know when you call us, so that we can properly identify our clients.

Only those individuals who need to do so as part of their job responsibilities are authorized to have access to your information. We regularly train our employees on privacy and information security, and on their obligations to protect your information.

We continually strive to maintain complete and accurate information about you and your accounts. If you ever believe that our records contain inaccurate or incomplete information
about you, please let us know immediately. We will correct any inaccuracies as quickly as possible.

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