Privacy Policy

Your Privacy Is Important to Zepeda & Company

In the course of serving you as an individual client or as someone associated with a corporate or institutional client, Zepeda & Company may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

This Policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information, and the steps that we take to safeguard the information to protect your privacy. As used throughout this Policy, the term “Zepeda & Company” refers to The Zepeda & Company Group, Inc. and its affiliates worldwide. The Sources of Information

The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to Zepeda & Company during the course of your relationship with us. We may also collect information about your transactions and experiences with Zepeda & Company relating to the products and services Zepeda & Company provides. In addition, depending on the products or services you require, Zepeda & Company may obtain additional information about you, such as your credit history, from consumer reporting agencies.

Finally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g., recording of telephone calls and monitoring e-mails). In these circumstances, the information is not accessed on a continuous or routine basis but it may be used for compliance or security purposes. The Information We Have About You

If you deal with Zepeda & Company in your individual capacity (e.g., as a private client), or as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, etc., the typical information we collect about you would include:

• Your name, address and other contact details; Your age, occupation and marital status; Extensive financial information, including source of wealth, investment experience and objectives, risk tolerance and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources ; A head and shoulders photograph from, as applicable, your passport, national identity card or driver's license, as required by laws and regulations addressing due diligence and related matters; and
• A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc.

If you are an employee/officer/director/principal, etc. of one of our corporate or institutional clients, the typical information we collect about you personally would include:

• Your name and contact details; Your role/position/title and area of responsibility; and
• Certain identifying information (e.g., passport photo, etc.) as required by laws and regulations addressing money laundering and related matters.

Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to open or maintain your account or to provide services to you. While we make every effort to ensure that all information we hold about you is accurate, complete and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.
 
Our Use of Your Personal Information

We may use your personal information to:

• Administer, operate, facilitate and manage your relationship and/or account with Zepeda & Company. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively; Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account; Provide you with information (such as investment research), recommendations or advice concerning products and services offered by Zepeda & Company; and
• Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

If your relationship with Zepeda & Company ends, Zepeda & Company will continue to treat your personal information, to the extent we retain it, as described in this Policy.

Disclosures of Your Personal Information Within Zepeda & Company

In order to provide efficient and reliable services, and to improve product and service options available to you, more than one entity within Zepeda & Company may be given, or given access to, your personal information. For example, one Zepeda & Company entity might share your information with another Zepeda & Company entity in order to facilitate settlement of your transactions or the maintenance of your accounts or as part of its arranging for the performance of specialized services such as U.S. and international brokerage, asset management, and advisory and trust services. When so sharing your personal information we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within Zepeda & Company is provided below under Information Security: How We Protect Your Privacy .
 
Disclosures of Your Personal Information to Third Parties

Zepeda & Company does not disclose your personal information to third parties, except as described in this Policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with Zepeda & Company, including those that provide professional, legal, or accounting advice to Zepeda & Company. Non-affiliated companies that assist Zepeda & Company in providing services to you are required to maintain the confidentiality of such information to the extent they receive it, and to use your personal information only in the course of providing such services and only for the purposes that Zepeda & Company dictates.

We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners, or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations, for instance, when responding to a subpoena or similar legal process, to protect against fraud, and to otherwise cooperate with law enforcement or regulatory authorities, or with organizations such as exchanges and clearinghouses.

You should know that Zepeda & Company will not sell your personal information. Information Security: How We Protect Your Privacy

Zepeda & Company is committed to implementing the highest standards of information security to protect the privacy and confidentiality of your personal information. We limit access to your personal information to authorized Zepeda & Company employees or agents and, as described above in Disclosures of Your Personal Information to Third Parties, our service providers are held to stringent standards of privacy. We also maintain physical, electronic, and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure. Some of the other central features of our information security program are:

• The use of specialized technology such as firewalls; Testing of the security and operability of products and services before they are introduced to the Internet, as well as on-going scanning for publicly-known vulnerabilities in the technology; Internal reviews of our Internet sites and services; Monitoring of our systems infrastructure to detect weaknesses and potential intrusions; Implementing controls to identify, authenticate and authorize access to various systems or sites; Protecting non-public communications through encryption or other means; and
• Providing Zepeda & Company personnel with relevant training and continually updating our security practices in light of new risks and developments in technology.

Other Privacy Policies or Statements; Changes to Policy

This Policy provides a general statement of the ways in which Zepeda & Company protects your personal information. You may, however, in connection with specific products or services offered by Zepeda & Company, be provided with privacy policies or statements that supplement this Policy. This Policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised Policy will be effective immediately upon posting to our Web site. This version of the Policy is effective July 11, 2005.

Zepeda & Company may occasionally contact you by post, telephone, electronic mail, facsimile, etc., with details of products and services that we believe may be of interest to you. If you do not wish to be contacted in this way, if you wish to exercise your rights of correction and access, or if you require further information regarding our privacy policies and practices in the above-referenced regions please contact::Martha Zepeda President & CEOZepeda & Company, Inc.100 North Crescent Blvd; Garden Level, Beverly Hills, CA 90210

Tel: 310.385.4426/ Fax: 310.943.0397/Email: maz@mzepeda.com